The Government has launched a consultation on potential reforms to the UK’s whistleblowing framework, including proposals to introduce financial rewards for individuals who report economic crime to the Serious Fraud Office (SFO).

Published on 12 October 2026, the consultation raises important questions about how whistleblowers are protected, how concerns are reported and whether existing arrangements are effective.

While the prospect of financial incentives may attract attention, the consultation also presents an opportunity for organisations to examine their own approach to whistleblowing.

Whatever changes may follow, the key question will continue to be whether employees feel confident raising concerns with their employer and, just as importantly, whether organisations are seen to take those concerns seriously.

Whistleblowing as an Early Warning System

In practice, employees, contractors and other individuals working within an organisation are often the first to identify suspicious behaviour, financial irregularities, misconduct or weaknesses in internal controls, including the inappropriate handling of sensitive information, abuse of privileged access or activities that could compromise organisational security. These are also recognisable manifestations of insider risk, which remains a major challenge to corporate integrity and security.

It follows that when concerns are raised, recognised and assessed appropriately, organisations have an opportunity to intervene before a problem escalates.

A Whistleblowing Policy Is Often Not Enough

The main reasons individuals hesitate to report wrongdoing are that they fear adverse professional consequences, doubt that their concerns will be taken seriously, or believe that the individuals responsible for investigating a complaint lack sufficient independence.

For organisations, this creates the danger that, whilst policy may be class-leading, potentially valuable sources of information may be reluctant to step forward.

Building confidence also entails organisations demonstrating that disclosures are taken seriously, handled fairly, confidentially and consistently, with appropriate safeguards against retaliation. A wealth of research suggests that whistleblowers will share concerns with those they trust, which often includes their first-line manager. Yet, managers are often not trained or otherwise professionally equipped to know what to do at ‘first contact’, with whistleblowing being seen exclusively as a HR issue. Stepping outside the known chain of trust is often the most worrying decision for the whistleblower.

In a GSA Global whitepaper, Dr Brian Moore explores the important role whistleblowers can play in identifying insider risks, alongside the potential consequences when organisations fail to respond appropriately to disclosures. Read the whitepaper HERE.

What Should Boards and Senior Leaders Be Considering?

The Government’s consultation provides an opportunity for boards and senior leadership teams to review whether their whistleblowing arrangements work.

Key considerations include:

  • Confidence in reporting: Do employees and contractors understand how to raise concerns, and do they trust the process?
  • Can sensitive allegations be investigated without conflicts of interest?
  • Are serious concerns brought to the attention of the right individuals, including the board where necessary?
  • Are suitable safeguards in place for whistleblowers and others involved in investigations?
  • Are investigation findings used to address underlying weaknesses in governance, security and organisational culture?

Boards should also consider whether whistleblowing information is being assessed alongside other sources of organisational risk intelligence, rather than being treated as an isolated compliance activity.

Looking Beyond the Proposed Reforms

Organisations do not need to wait for legislative reform to assess whether their existing arrangements actually work.

At GSA Global, our experience across corporate investigations, insider risk management, due diligence and protective security enables us to support organisations in understanding and responding to complex and sensitive concerns.