HMRC Whistleblower Reward Program: Comprehensive Overview

The HMRC Whistleblower Reward Program — officially the Strengthened Reward Scheme — is the United Kingdom’s new tax whistleblower initiative, launched on November 26, 2025. Modeled on the U.S. IRS Whistleblower Program, it allows individuals who report serious tax avoidance or evasion to receive between 15% and 30% of the tax HMRC collects, provided the recovery is at least £1.5 million.

The Strengthened Reward Scheme is a fundamental redesign of how the UK government incentivizes individuals to report serious tax wrongdoing. Announced by HM Treasury alongside the Autumn Budget and effective November 26, 2025, the program replaces HMRC’s old system of small, opaque, discretionary payments with a U.S.-style model: rewards calculated as a fixed percentage of the tax actually recovered, with no upper cap on the amount a whistleblower can receive.

The program targets what HMRC calls serious non-compliance — typically involving large companies, wealthy individuals, and offshore or avoidance schemes. Its purpose is to close the UK’s “tax gap,” the difference between tax owed and tax collected, estimated at £46.8 billion for the 2023/24 fiscal year. HMRC is openly following the playbook of the U.S. Internal Revenue Service, whose whistleblower program has generated billions in recoveries since it was established in 2006. Full details are published in HMRC’s official guidance on GOV.UK.

HMRC whistleblowers can receive between 15% and 30% of the tax collected as a result of their information, excluding penalties and interest. To qualify for a reward, the information must lead to the collection of at least £1.5 million in tax.

There is no upper cap. Because the reward is tied to the recovery itself, a tip that helps HMRC collect £100 million could produce a reward of £15 million to £30 million. This is the single most important change from the prior system, under which HMRC paid informants modest sums with no set formula — a combined total of just £852,438 in the year ending March 31, 2025.

One critical caveat: rewards under the HMRC program are discretionary, not guaranteed. Even where every threshold is met, HMRC decides whether to pay and how much. This is a major difference from the U.S. IRS program, where qualifying whistleblowers have a legally enforceable right to an award — and it is one of the strongest reasons for HMRC whistleblowers to work with experienced counsel from the outset.

Anyone with specific, credible information about serious tax avoidance or evasion may report it to HMRC and be considered for a reward, provided they supply their contact details and the information leads to a qualifying recovery. The strongest submissions share three characteristics:

• Original information — details not already known to HMRC and not discoverable through its routine compliance processes.
• Insider-level specificity — first-hand knowledge of the scheme, the parties involved, and where the evidence sits, rather than general suspicion.
• A qualifying recovery — the information must enable HMRC to collect at least £1.5 million in tax that would not otherwise have been recovered.

Importantly, there is no requirement that the whistleblower be a UK citizen or resident. What matters is the quality of the information and the size of the recovery.

HMRC’s guidance sets out several circumstances in which a whistleblower cannot receive a reward, even if their information leads to a major recovery. You are excluded if:

• You provide the information anonymously — anonymous reports are accepted and investigated, but no payment will be made;
• You are or were a civil servant (or contracted to work in government) and obtained the information through that employment;
• You are the taxpayer involved in the evasion or avoidance, or you planned and initiated the conduct;
• The information is already known to HMRC or could have been identified through its routine processes;
• The reward might directly or indirectly fund illegal activity;
• You are required by law to disclose the information — or legally prohibited from disclosing it;
• You are acting on behalf of someone else; or
• The information comes from a person who would themselves be ineligible.

The anonymity exclusion catches many whistleblowers off guard. Unlike the U.S. SEC program, which permits anonymous reporting through an attorney, HMRC requires whistleblowers seeking a reward to identify themselves — making it essential to understand the confidentiality protections available before filing.

The discretionary nature of the HMRC reward is the decisive difference. In the United States, our founding partners litigated the cases that turned the IRS program into an enforceable rights-based system — including securing the landmark $104 million award for UBS whistleblower Bradley Birkenfeld, whose disclosures dismantled Swiss banking secrecy and led to the recovery of billions in back taxes. The UK has adopted the U.S. reward percentages without (yet) adopting the enforceable rights behind them, which places a premium on how a claim is prepared, documented, and presented.

HMRC states that all reports made under the program are private and confidential. Workers in the UK may also have protection from employment retaliation under the Public Interest Disclosure Act 1998 (PIDA), which allows a worker who suffers detriment or dismissal for making a protected disclosure to bring a claim before an employment tribunal.

These protections are real but limited. PIDA compensates retaliation after the fact rather than preventing it, contains no reward provisions, and does not apply to everyone with valuable information. The experience of our client Howard Wilkinson — the British trader who exposed the $230 billion Danske Bank money laundering scheme, the largest in history — shows how quickly confidentiality can fail: despite reporting properly through internal channels, his identity was leaked in retaliation. Whistleblowers considering an HMRC submission should have a confidentiality and protection strategy in place before making any disclosure, not after.

Reports under the Strengthened Reward Scheme are made through HMRC’s secure online form for reporting serious tax avoidance or evasion on GOV.UK. The process rewards preparation:

1. Provide contact details. You may report anonymously, but you must identify yourself to be eligible for any reward.
2. Be detailed and specific. Describe the suspected activity, the parties involved, how the scheme works, and the tax at stake. The form does not accept attachments, but you can tell HMRC what supporting evidence you hold.
3. Do not investigate on your own. HMRC instructs whistleblowers not to seek out additional information, alert the subject of the report, or attempt to obtain evidence unlawfully — information obtained illegally can destroy reward eligibility.
4. Do not follow up. After submission, HMRC asks that you not file duplicate reports or contact the agency for updates. HMRC will contact you only if it needs more information or if you become eligible for a reward.
5. Expect a long timeline. Serious tax investigations take years, and rewards are not paid until a case is fully closed.

Because the submission is effectively a one-shot opportunity — with no feedback loop and no appeal — the initial report must be as complete, credible, and well-organized as possible. This is where experienced whistleblower counsel adds the most value.

Yes — and in many cases they should evaluate this option first. Serious tax fraud rarely stops at one border, and U.S. whistleblower reward laws are available to non-U.S. citizens. Where the misconduct touches the United States — U.S. taxpayers hiding assets offshore, transactions clearing through U.S. banks, securities issuers, or commodities markets — a UK whistleblower may qualify under the IRS Whistleblower Program, the SEC Whistleblower Program, CFTC Whistleblower Program, or the FinCEN Whistleblower Program, all of which provide mandatory awards to qualifying whistleblowers.

Our firm’s cases prove the point. Howard Wilkinson, a British citizen working in Estonia, exposed a money laundering scheme that moved rubles through Danske Bank and into New York via U.S. correspondent banks — making U.S. enforcement channels available to him. Bradley Birkenfeld, a banker at Swiss institution UBS, received his record $104 million award under the U.S. IRS program. A whistleblower with information about serious tax evasion should have counsel assess every available avenue — HMRC, U.S. programs, or both in parallel — before filing anywhere, because the order and manner of disclosure can determine eligibility. Learn more on our United Kingdom whistleblower law page.

Because HMRC rewards are discretionary, the strength of the presentation matters enormously. An experienced whistleblower attorney can help you document and frame your information for maximum credibility and impact, protect your confidentiality before and after filing, avoid the pitfalls that destroy eligibility (anonymity, unlawful evidence-gathering, prior disclosure), and evaluate whether parallel U.S. claims offer a stronger, enforceable path to a reward.

Kohn, Kohn & Colapinto has spent decades building the U.S. whistleblower reward model the HMRC program now emulates. Founding partners Stephen M. Kohn and David K. Colapinto have secured some of the largest whistleblower awards in history and have represented international whistleblowers — including UK citizens — in the world’s most significant tax and money laundering cases. Our firm works on a contingency-fee basis: you pay nothing unless we recover a reward on your behalf.

If you have information about serious tax avoidance or evasion — in the United Kingdom, the United States, or anywhere it crosses borders — contact us today for a free, confidential consultation.

• HMRC, Guidance: Reporting serious tax avoidance or evasion (GOV.UK, November 26, 2025)
• IRS Whistleblower Office (IRS.gov)