The FCA's 2024/2025 Annual Report on whistleblowing is out - here's what you need to know

On Tuesday (24 June 2025) the FCA published its Prescribed Person’s Annual Report on whistleblowing (“24/25 Report”), which covers reports received and acted on with during the period 1 April 2024 – 31 March 2025 (the “24/25 Period”). 

In broad terms, the 24/25 Report underscores the FCA's commitment to protecting whistleblowers and aims to highlight the vital role and real impact of whistleblowers’ reports in exposing wrongdoing and maintaining the integrity of the financial sector, in an effort to encourage more reporting, which is a critical source of intelligence for the FCA.  

Unlike previous years’ Annual Reports, which were limited to reporting on data and actions taken in respect of reports received during the reporting period only, the FCA has for the first time also included information about all reports whose reviews were completed during the reporting period (regardless of when they were received). This slight shift in scope is welcome, and provides more valuable insight into the nature and extent of the FCA’s activity and responses to whistleblowers in the financial sector, as well as the volume, quality, and types of reports it receives. 

A few notable points include:

• Slight increase in whistleblowing reports: The FCA received 1,131 new whistleblowing reports in the 24/25 Period, marking a continued (if incremental) rise in disclosures in recent years (i.e. 1,046; 1,041; 1,086; and 1,124 in the periods from 20/21 through 23/24 respectively). Almost half of those reports (545) came through the FCA’s online reporting webform, which was launched in 2021, with the next most popular methods being email (227) and telephone (222).
• Nature of Allegations: The top issues reported included compliance (685 reports), fitness and propriety (478 reports), consumer detriment (355 reports), and organisational culture (348 reports). Other significant areas included consumer duty, systems and controls, data security, unauthorised business, and FSMA violations. 
  • Whistleblowing related to fraud may be of particular interest for firms preparing for the new UK ‘failure to prevent fraud’ offence (coming into force on 1 September 2025) – 14% of the reports received by the FCA in 24/25 concerned fraud (i.e. 159 reports), which was very slightly down from 177 such reports in 23/24.   
• Regulatory Action: Overall, 51% (908) of all whistleblowing reviews concluded during the 24/25 Period resulted in direct action against firms, demonstrating the FCA's commitment to addressing and mitigating harm within the financial sector. The FCA also provided anonymised examples of some actions taken in response to reports about:
  • A firm's operations, client advice, growth plans, and lack of consumer duty focus: a section 166 ‘skilled person’ review, which concluded with the firm committing to implement all of the skilled person’s recommendations.
  • Pressure-selling and directors driving a poor culture: an information request and meetings between directors and the FCA supervision team, which ultimately led to a  re-evaluation of sales processes and improved compliance with the consumer duty.
  • Mis-selling of unsuitable products: interactions with the FCA supervision team, which required a review of all client sales within a specific period, and action to prevent further consumer harm.
• Enhanced Feedback and updated guidance for whistleblowers: The 24/25 Report highlights the FCA’s efforts to improve the feedback given to whistleblowers, which it expects will increase transparency, engender trust, and encourage reporting. By way of example, the FCA now provides detailed feedback letters upon case closure, which explain the steps taken (or not taken) in response to the reported concerns as much as possible within confidentiality and other constraints. The FCA also flagged that it has updated its webpage to make it easier for would-be whistleblowers to find guidance on submitting reports.

Where are we in the debate around financial rewards for whistleblowers in the UK? Has the FCA shifted its stance? 

The debate around whether the UK ought to offer financial incentives to whistleblowers to secure actionable intelligence is far from new, but has heated up considerably since Nick Ephgrave QPM took over as Director of the Serious Fraud Office (SFO). In his first official speech in February 2024, he called for financial incentives for whistleblowers, alongside better use of assisting offenders, in order to achieve his ambition of speeding up SFO investigations and prosecutions and improving conviction rates. 

Ephgrave noted that from 2012, 700 UK nationals had chosen to travel to the US to blow the whistle, where whistleblower reward programmes are available and successful, and (in December 2024) he described UK law enforcement as “scrabbling around in the dark” without insider/whistleblower intelligence to guide authorities’ labyrinthine investigations forward. The SFO has since pledged to “explore incentivisation options for whistle blowers” in its five-year Strategy 2024-2029 (launched in April 2024), and also included ‘pushing’ for progress on reforming whistleblower incentivisation in its annual Business Plan (2025 - 26) as one of its key outputs for the year.

By contrast, the FCA has long expressed scepticism about (if not opposition to) the merits of whistleblower rewards. Following the UK Parliamentary Commission on Banking Standards’ 2013 report on ‘Changing Banking For Good,’ which recognised the need for “a significant shift in the cultural attitudes towards whistleblowing” and called for research into the impact of financial incentives in the US, the FCA and PRA jointly stated their strong opposition in 2014, arguing that there was “no empirical evidence of incentives leading to an increase in the number or quality of disclosures received by the regulators.”

Yet, there have been indications that attitudes may be softening – in February 2024, the FCA indicated that it would review its position and consult with the SFO on financial incentivisation, and in March this year, the UK’s tax authority (HMRC) announced plans for a whistleblower rewards system modelled on the US Internal Revenue System (IRS) Whistleblower Program, for individuals who blow the whistle on those engaged in serious non-compliance with tax obligations.

In December 2024, the Serious Organised Crime Anti-corruption Evidence Research Programme (SOC ACE) released a Research Paper explaining that whistleblower rewards have been empirically proven to enhance efforts against financial crime. The Research Paper also debunks several common misconceptions about whistleblower rewards and offers a series of recommendations to inform policy discussions on effectively implementing a reward scheme in the UK. The UK’s whistleblowing legislation was under review during the Sunak government and potentially faces reform, but legislative appetite for financial incentivisation remains unclear.

In the 24/25 Report, the FCA is keeping its powder dry, but making some encouraging noises – it explains that it has been exploring (and continues to explore) the potential benefits of incentivising whistleblowers by engaging with other UK regulators, government departments, and international partners to understand the implications of incentivisation programmes. 

Key takeaway

Whistleblowing ‘externally’ to UK authorities like the FCA is steadily increasing, but may grow significantly in the event that any financial incentive programmes are introduced. Corporates should therefore ensure that their internal whistleblowing frameworks are an attractive, trusted, and encouraged alternative, so that whistleblowers are inclined to report internally in the first instance, which will give the organisation an opportunity to assess and address issues quickly and effectively, and/or prepare appropriately for engagement with relevant authorities.

The FCA's 24/25 Report is available here.

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