The financial reward element borrows from schemes already running in the United States and Canada. Where a tip-off leads to a conviction or enforcement action over fraud, bribery or other economic crime, the person who raised it could receive a percentage of the fine. The consultation doesn’t settle on a figure and specifically asks whether there should be a cap at all. HMRC already runs a smaller version of this through its own tax evasion tip-off scheme, which can pay out up to 30% of the amount recovered.
The second proposal is the one that should get more attention from workplace, FM and property employers. It would introduce a statutory duty requiring certain employers to hold a written whistleblowing policy and to follow up properly on anything reported through it. Government is weighing up where that line should sit: private employers with 50 or more staff, all public sector organisations, or some combination of the two. The alternative on the table is simply updating guidance rather than creating a new legal duty, which would leave compliance effectively optional.
Large FM and property operators already run some version of a whistleblowing channel, usually a hotline number buried in an induction pack or a line in the employee handbook nobody reads twice. Few treat it as a process with the same rigour as a safety incident report: logged, timed, escalated and closed out with evidence. A statutory duty would change that calculus. An employer with a documented policy and a record of following up looks very different to a regulator, or an employment tribunal, than one that can only point to a page on the intranet.
This lands with particular force for employers running large, dispersed, outsourced or multi-site workforces, which describes most of the facilities management sector. Cleaning, security, catering and maintenance staff spend their working day on someone else’s premises, often with limited contact with their own employer’s management structure. If something goes wrong on a client site, whether that’s a safety cover-up, a procurement kickback or a financial irregularity, the person best placed to notice it is often the frontline worker furthest from head office. A policy that doesn’t reach that worker in practice isn’t much of a policy.
The reward scheme adds a separate pressure. If whistleblowers stand to gain from reporting externally to the Serious Fraud Office, the incentive to raise concerns internally first weakens unless the internal route is demonstrably worth using. That’s a reason to get ahead of this rather than wait for a statutory duty to force the issue.
The consultation runs to 8 January 2027, and nothing in it is final. There’s no guarantee government lands on a statutory duty rather than updated guidance, and no indication yet of where a 50-employee threshold would sit relative to FM contractors whose headcount scales up and down between contracts. Organisations with a view on where the line should fall, or on what “appropriate and effective” procedures should mean in practice, have until January to respond.
In the meantime, it’s a reasonable prompt for any HR or compliance team to check what their own whistleblowing arrangements would look like under scrutiny. A policy that hasn’t been reviewed since before the Employment Rights Act 2025 started landing its provisions this autumn is probably due one anyway.
Does this apply to my organisation now? No. The proposals are at consultation stage, closing 8 January 2027. No statutory duty exists yet.
Who would the new duty apply to? Government is consulting on applying it to private employers with 50 or more staff and all public sector bodies, though the final scope hasn’t been decided.
How would the reward scheme work? Modelled on schemes in the US and Canada, it would pay a share of any fine the Serious Fraud Office recovers to the person whose information led to the conviction. The consultation asks whether that share should be capped.
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