The State of the World’s Whistleblower Laws, Protections, and Rewards

by Kyla Golding and Matthew P. Suzor

In 2003, the United Nations adopted the Convention Against Corruption (“UNCAC”). Signed by 140 nations and formally ratified, accepted, approved, or acceded by 137 nations, including the United States, this Convention recognized whistleblower protection as a part of international law. 23 years later, with World Whistleblower Day having recently occurred on June 23, 2026, the scope of what it means to be a “whistleblower” and the protections for those who “blow the whistle” still vary widely around the world.

A whistleblower is generally defined as a person who discloses information about wrongdoing, including violations of law, to competent authorities in good faith and on reasonable grounds. For instance, a whistleblower can be an employee who alleges that misconduct by their employer violates public law or may be causing (or may have caused) harm to the public. A whistleblower might either blow the whistle internally to authorities within the same organization, or to external regulatory bodies, including law enforcement agencies.

Whistleblowers around the world can play a critical role in exposing misconduct, illegal activities, or regulatory violations that, per the UNCAC, “undermine[] democracy and the rule of law, lead[] to violations of human rights, distort[] markets, erode[] the quality of life.”  Whistleblowers may be eligible to receive rewards pursuant to laws designed to protect and encourage insiders to report misconduct to safeguard the public interest.

Many conventions and international organizations around the world have supported whistleblower rights and protections becoming part of international law and have lobbied for greater international adoption of whistleblower laws and best practices. Nevertheless, whistleblower laws, protections, and rewards still differ significantly in scope, reach, and recovery around the world.

The American Reward Model

In the United States, there are dozens of laws at the federal, state, and local levels designed to encourage whistleblowers to come forward and protect disclosures that reasonably evidence wrongdoing such as violations of law, rules, or regulations. Examples include, inter alia, failure to adhere to United States Environmental Protection Agency regulations, United States Office of Occupational Health and Safety standards, or financial reporting requirements and falsifying certifications made to the government for payment. In 2015, the National Whistleblower Center published a report entitled Whistleblower Reward Programs: An International Framework for the Detection of Corruption and Fraud which identified that U.S. whistleblower reward laws are highly effective at incentivizing whistleblowers to report fraud.

The False Claims Act, 31 U.S.C. §§ 3729 – 3733 (“FCA”), establishes that any person who knowingly submits, or causes to submit, false claims to the government, or knowingly uses a false record material to a false claim or improperly avoids an obligation to pay the government, is liable for three times the government’s damages plus a penalty linked to inflation for each false claim submitted. The FCA allows private citizens to blow the whistle and file qui tam suits, on behalf of the government, against those who have defrauded the government. Whistleblowers who successfully bring qui tam actions may receive a portion of the government’s recovery. The United States Department of Justice obtained more than $2.9 billion in settlements and judgments from civil cases brought under the FCA in 2024 alone.  Additionally, several states and jurisdictions across the United States have implemented their own False Claims Acts, including, inter alia, New York, California, the District of Columbia, Massachusetts, Texas, Illinois, and Delaware.

In addition to the FCA, the Internal Revenue Service (“IRS”) has its own whistleblower program. Pursuant to the Internal Revenue Act, the Secretary of the Treasury is allowed to pay such amounts as it deems necessary “for detecting and bringing to trial and punishment persons guilty of violating the internal revenue laws [and underpaying tax, per the 1996 amendment] or conniving at the same.” In 2006, the Tax Relief and Health Care Act was passed, establishing a framework for the consideration of whistleblower submissions and establishing the Whistleblower Office within the IRS to make final award decisions on behalf of the IRS and Department of Treasury. If proceeds are recovered by the IRS using information attributable to a whistleblower’s tip, the whistleblower may be awarded 15 to 30% of the proceeds collected. In 2024, the IRS paid whistleblower awards totaling $123.5 million attributable to information that resulted in proceeds collected $474.7 million.

In the aftermath of the financial crisis of 2008 and 2009, the Dodd-Frank Act (“Dodd-Frank”) was passed in 2010, covering commodities and securities actions. Dodd-Frank established created two whistleblower programs in the U.S. Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”). Under Dodd-Frank, a whistleblower may file a complaint – containing original information derived from independent knowledge or analysis – with the SEC or CFTC. If the agency chooses to investigate, confirms the validity of the whistleblower’s complaint, and sanctions the wrongdoer for $1 million or more, the whistleblower may be entitled to between 10% and 30% of any recovery made by the SEC or CFTC. In 2025, the SEC awarded a total of more than $60 million to whistleblowers. Since 2014, the CFTC has awarded more than $430 million to whistleblowers associated with enforcement actions that have resulted in more than $3.7 billion in monetary sanctions.

Not only does the United States have various whistleblower laws, programs, and rewards systems, there are also various whistleblower protections. Under the FCA, for example, employers are prohibited from retaliating against employees who engage in protected activities related to the FCA. Moreover, under the Unites States Department of Labor’s whistleblower protection laws an employer cannot retaliate against a whistleblower for reporting issues relating to, among other things, employee safety, consumer product and food safety, environmental protection, fraud and financial issues, health insurance, identifying hazards, filing a discrimination complaint, opposing practices made unlawful by equal opportunity laws, minimum wage, overtime pay, and family and medical leave.

Whistleblower Protections and Rewards in the United Kingdom

In the United Kingdom (“UK”), making a whistleblower disclosure or protected disclosure includes reports of dangers to public interest such as fraud or health, safety, and environmental risks. Generally, whistleblowers may disclose the wrongdoings of their employer to a prescribed person or body, i.e. the appropriate authority that deals with the specific issue being raised. For example, a disclosure about wrongdoing in a care home can be made to the Care Quality Commission and disclosures about serious, complex fraud or bribery and corruption involving a British company, charitable organization, or central or local government departments, can be made to the Serious Fraud Office (“SFO”).

Whistleblowers in the UK are protected from retaliation under the Public Interest Disclosure Act (“PIDA”). The PIDA protects any worker who makes protected disclosure and is thereafter subject to any form of retaliation from their employer for raising their concern. Under the PIDA, if a worker experiences retaliation for making a whistleblowing disclosure, they have the right to compensation at an employment tribunal.

Though whistleblowers may be protected from retaliation, the UK provides little financial incentive, such as whistleblower rewards, for whistleblowers to make protected disclosures. In November 2025, however, the House of Commons announced the launch of the Strengthened Reward Scheme, a new whistleblower program “modeled on the U.S. [IRS] scheme,” which makes way for “informants who provide valuable information which allows HM Revenue and Customs (“HMRC”) to tackle high-value [tax] avoidance or evasion” to receive a reward. In instances where HMRC recovery is over £1.5 million, whistleblowers may receive a reward up to 30% of that recovery.

Interestingly, a few months earlier in September 2025, the UK effectuated the Failure to Prevent Fraud (“FTPF”) offence, Sections 199-206 and Schedule 13 of the Economic Crime and Corporate Transparency Act of 2023 (“ECCTA”). The FTPF offence closely mirrors the principles of the FCA, as the offence imposes strict liability on “large organizations” for specified fraud offences committed by an “associated person” which includes employees, subsidiaries, or agents acting on their behalf. The ECCTA does not specify that only certain bodies can bring a suit, in practice, in the UK, the SFO is the primary prosecuting authority for corporate offences. Therefore, unlike with the FCA, a private citizen may not have much headway to independently, on behalf of the government, prosecute an organization under ECCTA for the FTPF offence. Though authorized prosecuting authorities such as the SFO or other designated law enforcement bodies are the primary bodies bringing criminal proceedings for offences like FTPF, whistleblower tips may be of great assistance in exposing misconduct.

The EU Whistleblower Protection Directive

In October 2019, the European Union (“EU”) released the Whistleblower Protection Directive, which set minimum standards for member states to provide protection from retaliation to individuals who report breaches of EU law. Under the Whistleblower Protection Directive, whistleblower protection covers individuals who report breaches of EU law across various policy areas including public procurement, financial services and anti-money laundering, product safety, transport safety, environmental protection, consumer protection, or fraud involving EU funds, violations related to the internal market, including EU competition rules, state aid regulations, and corporate tax arrangements designed to gain a tax advantage that undermines applicable corporate tax law.

As of June 2024, all EU Member States had passed legislation to transpose the Directive. The Directive is meant to ensure that “(i) whistleblowers have at their disposal effective channels to report breaches of EU rules confidentially, both internally (within organization) and externally (to a competent authority), (ii) whistleblowers’ reports are properly investigated and acted upon by the organizations and competent authorities; and that [and] (iii) whistleblowers are protected from retaliation itself does not mandate or provide whistleblower rewards.”] The Directive centers on protection, confidentiality, and effective reporting mechanisms, but does not suggest or mandate any financial incentives for whistleblowers.

Whistleblower Programs in South Korea and Across Asia

South Korea has a tax whistleblower program that predates the U.S. IRS Whistleblower Program. Enacted in 1951, and administered by the National Tax Service, South Korea has two whistleblower reward programs: the Tax Evasion Informant Reward Program and the Foreign Financial Account Report Reward Program. Through the Tax Evasion Informant Reward Program, a whistleblower may receive 5% to 20% of the recovery up to $2.7 million USD, if the monetary sanctions assessed against the tax evader pursuant to the whistleblower’s information must exceed $34,000 USD. Through the Foreign Financial Account Report Reward Program, a whistleblower may receive 5% to 15% of the recovery, up to a maximum of $1.3 million USD if he or she provides information regarding offshore tax evasion exceeding $676,000 USD. Even more, individuals of any nationality are eligible for awards under South Korea’s whistleblower programs. These tax whistleblower programs have resulted in whistleblower rewards amounting to $44 million in just the last seven years.

More broadly, all of South Korea’s whistleblower programs have been reaffirmed by significant legislative developments such as the Act on the Prevention of Corruption and the Establishment and Management of the Anti-Corruption and Civil Rights Commission of 2008 (“ACRC Act”) and the Act on the Protection of Public Interest Whistleblowers of 2011 (“PPIW”), which provide legal framework for whistleblowing procedures and extends anti-retaliation safeguards to public and private sector whistleblowers, respectively. Under the ACRC Act, if a public-sector whistleblower’s disclosure leads to a substantial financial benefit to the government or greatly benefits the public interest, whistleblowers can be recommended by a public institution or by the ACRC to receive an award up to $88,000 USD. Under the PPIW, if a private-sector whistleblower’s disclosure directly results in recovery, the whistleblower is entitled to a reward of up to $3 million USD from the ACRC. Since 2008, pursuant to these programs, whistleblowers have been awarded $22 million USD.

Elsewhere in Asia, though whistleblower laws and protections exist, enforcement of whistleblower legislation and protection for whistleblowers is less robust. For instance, India has the Whistle Blowers Protection Act of 2014 which outlines the legal framework for whistleblowing processes and protections, however private sector pushback and gaps in compliance legislation make it hard to protect private-sector whistleblowers.

Ghana and the Whistleblower Reward Fund

In Ghana, the Whistleblower Act, 2006 (Act 720) (“Act 720”) provides a legal framework for whistleblowing as it outlines multiple reporting channels and procedures as well as prohibits any form of retaliation against whistleblowers. Moreover, Sections 20-27 of Act 720 establish a Whistleblower Reward Fund. Under Act 720, a whistleblower may receive a monetary reward if their disclosure leads to a conviction or monetary recovery. The reward can be up to 10% of the recovery.

 A Global Outlook

Twenty-three years after the United Nations adopted the Convention Against Corruption, recognizing whistleblower protection as a part of international law, countries around the world have opted to enact whistleblower laws and protections or further reaffirm and reform pre-existing whistleblower legislation. Nevertheless, issues of retaliation, public versus private sector polarization, and the discretion of enforcement channels still create challenges for whistleblowers on a global scale. While some jurisdictions have enhanced their rewards systems and strengthened their anti-retaliation legislation, the world has yet to fully embrace whistleblowing a means for combating corruption and necessity of the channel to be protected.