SFO Enforcement Update 2025-2026: What Corporates & Advisers Need to Know

The Serious Fraud Office under Director Nick Ephgrave has adopted a markedly more proactive enforcement posture. The SFO 2025-26 Strategic Plan records 8 new investigations opened in 2025 and 5 cases listed for trial in 2026, signalling sustained activity across corporate fraud, bribery, and financial crime.

Updated SFO/CPS corporate self-reporting guidance (2025) states explicitly that where a corporate self-reports suspected wrongdoing and fully cooperates, it can expect to be invited to negotiate a DPA rather than face prosecution, unless exceptional circumstances apply. Cooperation now includes facilitating access to overseas data and waiving privilege over factual accounts.

The Failure to Prevent Fraud offence under ECCTA 2023 came into force on 1 September 2025, creating new corporate criminal exposure. Forensic accountants support corporates assessing self-reporting decisions, quantifying misconduct scope, and preparing financial evidence for DPA negotiations.

Whistleblower incentives have expanded: HMRC's Strengthened Reward Scheme offers 15-30% of tax recovered over £1.5 million. UWO enforcement remains active, with the annual report published in February 2026. Cryptoasset firms face full FCA regulation from October 2027.