Helping HMRC — UK’s Tax, Payments and Customs Authority — Build an Effective Whistleblower Program

Benjamin Calitri and Kate Reeves of NWC publish UK Whistleblowers Flock To The US For Good Reason in Law360, responding to SFO Director Nick Ephgrave’s call for whistleblower awards in the UK.

This article documents why UK whistleblowers turn to American authorities: between 2011 and 2021, UK whistleblowers submitted 783 tips to the SEC — more than any other country outside North America. It traces the cause to the Public Interest Disclosure Act’s failures, including the absence of anonymity protections, a 4% success rate at employment tribunal, and the lack of any financial rewards.

The article concludes that the UK must provide statutory guarantees for anonymity and confidentiality, adopt award provisions based on the value of whistleblowers’ information, and establish an Office of the Whistleblower — reforms that would transform whistleblowing from a risky endeavor into an effective anti-corruption tool.

Eliza Lockhart of the Royal United Services Institute (RUSI): The Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime, publishes The Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime.

This research analyses the impact of whistleblower reward programmes and scrutinises whether the concerns that have been raised regarding their implementation have eventuated in practice.

Furthermore, it considers what factors have been shown to be necessary for such a scheme to operate as part of a wider strategy to increase the effectiveness of economic crime investigations and concludes with observations for policymakers considering the introduction of whistleblower rewards.

James Murray’s speech, March 11, 2025. The speech was delivered at a joint ICAEW and CIOT conference marking HMRC’s 20th anniversary, held at the Chartered Institute of Taxation. 

In it, Murray announced that HMRC would launch a new reward scheme for informants later that year, targeting serious non-compliance in large corporates, wealthy individuals, offshore and avoidance schemes.

Benjamin Calitri publishes “What the US can teach the UK on whistleblowing” in The Banker, reflecting on his time in London at Whistleblower Awareness Week, where he was repeatedly told that whistleblower rewards are “not British.”

The article dismantles that objection: the UK is a hub for an estimated 40 per cent of the world’s dirty money, loses £5.5bn a year to tax evasion, and, under PIDA, sees 97 per cent of whistleblowers lose at employment tribunal. Meanwhile, US reward programmes have paid out over $16bn as of 2023 — with the SEC alone paying $224mn in 2024 — while protecting whistleblowers’ anonymity and confidentiality throughout the process.

Citing RUSI’s finding that reward programmes would be effective in the UK, Calitri notes that both the SFO and HMRC are working to establish rewards programmes and urges them to follow RUSI’s recommendations, including mandatory rewards.

He argues it is the rich and powerful with dirty money to hide who benefit from the claim that rewards are “not British” — because rewards make whistleblowing profitable and corruption unprofitable.

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Following a July 22, 2025 meeting where HMRC shared its plans for the informer rewards program, NWC submits formal recommendations for the program’s design. The document lays out five recommendations:

• Specified reasons for disqualification — modeled on the Dodd-Frank Act’s exclusion categories
• A presumption of paying awards when informers meet all criteria, to build trust and increase both program use and informer cooperation
• Confidentiality guarantees duplicated from the US SEC, CFTC, and AML whistleblower programs
• The two central tenets of successful reward programs — no upper cap on awards with a 10–30% range, and minimizing discretion to deny awards, including prohibiting the size of an award from being used as a factor against approval
• Dedicated funding by earmarking 5% of all collections from whistleblower cases for the whistleblower office itself

The recommendations note NWC was pleased to learn HMRC was seriously considering no upper cap and a Dodd-Frank-style percentage range — provisions that ultimately appeared in the final scheme launched in November 2025.

NWC sends a letter to James Murray MP, Exchequer Secretary to the Treasury, following a meeting with his staff to discuss HMRC’s plans for informer rewards.

The letter outlines NWC’s core design recommendations for the scheme: specified disqualification criteria, a presumption of paying awards when criteria are met, guaranteed confidentiality, no cap on awards, a dedicated office of the whistleblower, and a guaranteed funding mechanism.

Its central warning concerns discretionary awards. Drawing on decades of US experience, NWC explains that discretionary programs failed and were replaced by mandatory ones — the IRS program was made mandatory in 2006, the SEC’s in 2010, and the AML Whistleblower Program in 2022, after NWC briefed Congress on the importance of mandatory awards, an argument unanimously adopted by the Senate.

The letter also recommends funding the program from recoveries collected from tax evaders themselves, citing the CFTC Whistleblower Office model, which generated a gross operating profit of more than $2.6 billion in its first ten years — ensuring the program is funded by tax evaders rather than taxpayers.

Chancellor Rachel Reeves announces the Strengthened Reward Scheme during the 2025 Budget Statement in the House of Commons, with HM Treasury formally launching the program alongside the Autumn Budget and HMRC publishing guidance that November.

Modeled on the US IRS Whistleblower Program, the scheme pays whistleblowers 15% to 30% of the tax HMRC collects when their report leads to a recovery of at least £1.5 million — with no upper cap on rewards. It targets serious non-compliance by large corporations and wealthy individuals, including the misuse of offshore accounts and tax avoidance schemes, and requires original, credible, verifiable information that leads to the recovery of tax that would not otherwise have been collected.

The scheme is a fundamental redesign of HMRC’s old approach, which relied on small, opaque, discretionary payments — paying out less than £1 million per year despite receiving more than 160,000 reports of suspected tax fraud. The Government estimates the first rewards will be paid in 2027/28, with £225 million in additional tax collected by the end of 2030/31, potentially paying £96 million in rewards over the same period.

Notably, rewards remain at HMRC’s discretion and are not guaranteed — whistleblowers receive no feedback on their disclosure, no updates on the investigation, and have no right of appeal if HMRC declines to make an award. The scheme came into effect on April 6, 2026.