The UK now pays whistleblowers. Sort of.

On 26 November 2025, the UK government launched what it calls the Strengthened Reward Scheme for tax whistleblowers — or, as HMRC prefers, "informants." Announced in the Autumn Budget, it offers 15–30% of additional tax recovered in cases exceeding £1.5 million. The headlines wrote themselves: Britain finally adopts a US-style whistleblower programme.

The reality is more complicated. The scheme is a genuine step forward from a system that paid out less than £1 million to all informants combined in 2023/24 — against an estimated tax gap of £46.8 billion. But it has structural limitations that anyone considering a disclosure needs to understand before deciding where to file.

What the scheme offers

The scheme targets serious tax avoidance and evasion involving large companies, wealthy individuals, and offshore or avoidance structures. If your information leads HMRC to recover at least £1.5 million in tax, you may receive between 15% and 30% of the tax collected, excluding penalties and interest. There is no published upper cap on the reward.

Reports are made through HMRC's online reporting service at gov.uk. HMRC will acknowledge receipt, follow up if it needs more information, and contact you if you are eligible for a reward. The government estimates the first rewards will be paid in 2027/28 and projects £225 million in additional tax collected by 2030/31.

What the scheme doesn't offer

This is where it gets difficult.

Awards are discretionary. The word in the HMRC guidance is "could" — not "shall." Under US law, above the $2 million threshold, the IRS is required by statute to pay between 15% and 30%. The whistleblower has a legal right to that payment and can challenge the determination in the US Tax Court. Under the HMRC scheme, the decision to pay — and the amount — rests entirely with HMRC. There is no published appeals process. There is no independent adjudicator. HMRC is simultaneously investigator, beneficiary, and paymaster.

Anonymous reporters are excluded from rewards. HMRC's own guidance states plainly: you can report anonymously, but you will not be eligible for a reward. You must provide contact details to qualify. For someone sitting inside a multinational, aware of serious tax fraud, weighing whether to come forward — this is a material deterrent. The entire value proposition of the scheme depends on people identifying themselves to the authority that will investigate their employer.

There is no dedicated anti-retaliation framework. The UK's existing whistleblower protection relies on the Public Interest Disclosure Act 1998, which places the burden on the individual to bring a claim in an Employment Tribunal after retaliation has occurred. There is no government-enforced prohibition, no federal cause of action, and no penalty for employers who retaliate. Contrast this with the Taxpayer First Act in the US, which makes it illegal for an employer to discharge, demote, threaten, or discriminate against a whistleblower, with a private right of action in federal court.

Civil servants and government contractors are excluded entirely — even former ones. If you obtained information through government work at any point, you cannot receive a reward. This removes an entire category of people who routinely encounter tax fraud through regulatory, audit, or administrative functions.

The rewards exclude penalties and interest. Under the US programme, the 15–30% award is calculated on collected proceeds including penalties and interest — which in large cases can exceed the underlying tax. HMRC's scheme strips both out, significantly reducing the potential award on any given case.

Investigations take years, with no mechanism to compel action. HMRC's own guidance warns that there could be years between filing a report and receiving any payment. There is no transparency about case progress, no obligation to investigate within a timeframe, and no published mechanism for challenging a decision not to act.

Why this matters

The SFO's director, Nick Ephgrave, has been unusually candid about why the UK needed this scheme. Since 2012, over 700 UK nationals have gone to the United States to blow the whistle because the UK offered neither meaningful rewards nor adequate protection. The information went where the incentives were.

The new scheme is designed to reverse that flow. Whether it will succeed depends on whether HMRC can build enough trust that potential whistleblowers believe — on the strength of a discretionary promise — that they will actually be paid, actually be protected, and that the years-long process will eventually deliver something proportionate to the risk they took.

The legal community is watching carefully. WilmerHale described the scheme's significance as lying primarily in the "direction of travel" — a shift in what is politically acceptable in the UK, rather than a finished framework. Clifford Chance noted that it may provide a model for the SFO and other agencies. Protect, the whistleblowing charity, warned that rewards are no substitute for a comprehensive protection framework and that only a tiny minority of whistleblowers in the US have ever received anything.

All of this is fair. It is also worth noting that under the old scheme, HMRC paid out less than a million pounds a year while the tax gap ran to tens of billions. The Strengthened Reward Scheme is better than what preceded it. But "better than nearly nothing" is a low bar.

If you have information about a UK company

Here is the question that matters: does the company also have US tax obligations?

If it earns revenue in the United States, is listed on a US exchange, has American operations, or trades in dollars through US-connected institutions — it almost certainly does. And if the conduct you've witnessed involves the same money moving through the same structures, you may have a choice about where to file.

Under US law, the award is mandatory, uncapped, includes penalties and interest, and is subject to independent judicial review. You can file anonymously through counsel. You are protected by statute against retaliation. The IRS Whistleblower Office has paid out over $1.3 billion since 2007. The SEC programme has paid out over $2 billion since 2011.

Under UK law, the award is discretionary, excludes penalties and interest, requires you to identify yourself to HMRC, offers no dedicated retaliation protection, and has no independent appeals process. The scheme went live in November 2025. No rewards have yet been paid.

In some cases, the same information could qualify under both jurisdictions. The question is which route offers the strongest combination of financial incentive, legal protection, and institutional credibility.

We can help you work that out — anonymously, at no cost, and with no obligation.

If your company operates in the United States — earns revenue there, is listed on a US exchange, has American subsidiaries, or routes dollar transactions through US-connected banks — you almost certainly have a choice about where to file. We can assess your information against both the UK and US programmes and tell you which route is strongest. Most of the time, for the reasons set out above, it will be the US. But we'll give you the honest answer either way.

Side-by-side comparison

	United States (IRS §7623)	United Kingdom (HMRC Strengthened Reward Scheme)
Award range	15–30% of collected proceeds	15–30% of tax collected
Mandatory?	Yes — "shall" in statute	No — discretionary
Includes penalties & interest?	Yes	No
Minimum threshold	$2 million in dispute	£1.5 million in tax recovered
Award cap	None	None published
Anonymous filing?	Yes — through counsel	No — must identify to qualify for reward
Anti-retaliation	Taxpayer First Act — federal cause of action	PIDA 1998 — Employment Tribunal, burden on individual
Appeals process	US Tax Court	None published
Track record	$1.3 billion paid since 2007 (IRS); $2 billion+ since 2011 (SEC)	Scheme launched November 2025 — no awards paid yet
Non-citizens eligible?	Yes	Yes (but must identify to HMRC)

Sources

HMRC, "Reporting serious tax avoidance or evasion", 26 November 2025.
HMRC, "Report tax fraud or avoidance to HMRC", gov.uk.
Clifford Chance, "A Sign of Things to Come? HMRC Launches Informants' Rewards", December 2025.
WilmerHale, "Budget 2025: HMRC Whistleblower Scheme a Welcome Change", 2 December 2025.
Skadden, "UK To Create Whistleblower Incentives To Boost Tax Collection", December 2025.
Protect, "Press statement: New HMRC whistleblowing rewards scheme", 26 November 2025.
Macfarlanes, "New HMRC reward scheme for whistleblowers introduced", November 2025.
Kohn, Kohn & Colapinto, "HMRC Launches Strengthened Tax Whistleblower Reward Scheme", 2 December 2025.

This page was last updated on 14 February 2026. It reflects the scheme as launched on 26 November 2025. HMRC may issue further guidance; we will update this page accordingly.