United Kingdom “Prescribed Persons” Model under PIDA & Proposed Reform Bill
1. The Current Framework: “Prescribed Persons” under PIDA
Under the Public Interest Disclosure Act 1998 (PIDA), UK workers can make “protected disclosures” reports in the public interest—if they reasonably believe the information indicates wrongdoing (e.g., criminal offences, legal breaches, health/safety risks, environmental harm, or cover‑ups)
One such avenue is disclosure to “prescribed persons” regulators or professional bodies formally designated by law to receive whistleblower reports. The Prescribed Persons Order 2014 establishes the current list, including entities like the Health and Safety Executive, Environment Agency, Financial Conduct Authority, and HM Revenue & Customs
Key characteristics:
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This route offers reporters a confidential, statutory channel outside of internal corporate structures.
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Prescribed persons must publish annual reports summarizing disclosures received, actions taken, and their impact enhancing transparency and accountability
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Nonetheless, prescribed persons do not have a legal obligation to investigate or act upon disclosures, and many whistleblowers report inadequate follow-through, leaving concerns unresolved and eroding trust
2. Reform on the Horizon: The “Office of the Whistleblower” Bill
In response to growing criticism that PIDA is outdated, fragmented, and heavily reliant on post-dismissal tribunal claims, legislative reform is now underway.
The Office of the Whistleblower Bill, introduced in December 2024 by MP Gareth Snell, seeks to overhaul the system by establishing an independent statutory office responsible for:
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Setting, monitoring, and enforcing whistleblowing standards;
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Providing advice and disclosure services to whistleblowers;
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Directing investigations and ordering redress for those harmed by whistleblowing matters
This Bill is scheduled for its second reading in Parliament on 11 July 2025, marking a significant milestone in the reform process
Supporters argue the Bill offers a much-needed centralizing body, improved anonymity protections, and more proactive case handling than currently possible under the employer-centric PIDA route
However, critics point out notable gaps:
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It lacks financial incentive schemes for whistleblowers something lauded in the U.S., and desired even by UK law enforcement figures like the SFO director
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Provisions for managing caseloads, prioritizing cases, or handling complexity are not clearly defined and may overload already stretched authorities
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Some argue the new body won’t go far enough, as many detriments and risks whistleblowers face remain unmitigated under the current draft
3. Summary: Where Things Stand and What’s Next
| Aspect | Under PIDA (Prescribed Persons) | Under Proposed Reform Bill |
|---|---|---|
| Reporting Channels | Multiple fragmented statutory bodies (prescribed persons) | Centralized through a dedicated independent Office of the Whistleblower |
| Investigation Power | Optional for prescribed persons; no duty to act | Office would direct and enforce investigations |
| Protection Mechanism | Tribunal-based after detriment—reactive, slow, costly | Office can provide proactive support, advice, and redress |
| Transparency | Annual reports by prescribed persons | Potential for aggregated national data and standardized oversight |
| Incentives | None—no financial or systemic rewards for whistleblowers | None proposed—lack of incentive noted as a key omission |
The UK’s current whistleblowing framework the “prescribed persons” model under PIDA offers legal protection and multiple external reporting routes, albeit with limitations in follow-through and employer responsiveness. The proposed Office of the Whistleblower Bill marks an ambitious step toward a centralized, enforceable, and supportive system. Still, it may fall short in incentivizing disclosures and defining operational effectiveness.
At‑a‑glance
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No single national authority today. The UK relies on the Public Interest Disclosure Act 1998 (PIDA) and a list of “prescribed persons” (sector regulators) who receive protected disclosures (e.g., FCA, HSE, Ofcom, NHS bodies).
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Reform under consideration: Office of the Whistleblower Bill proposes a new independent authority to set/enforce standards, direct investigations, and order redress.
Legal basis & scope
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PIDA protects “workers” making protected disclosures of specified wrongdoing. The Prescribed Persons Order (amended periodically, including 2025) updates which regulators can receive disclosures.
How to report
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Internally to the employer; or externally to the relevant prescribed person. MPs and legal advisers are also routes; limited public disclosures can be protected where strict tests are met.
Protections & enforcement
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Protection from detriment/dismissal; employment tribunals can award uncapped compensation. Prescribed persons must publish annual reports on disclosures received.
Recent developments to know
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Government review of the GB whistleblowing framework published (2025) with evidence on effectiveness; prescribed persons list updated; cross‑party attention on creating a central Office of the Whistleblower.
Employer checklist
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Map relevant prescribed persons; ensure safe channels and clear guidance; train managers; monitor FCA/PRA expectations if in financial services (e.g., whistleblowing champion responsibilities).
