Reports to the Protected Disclosures Commissioner on the Rise

The Protected Disclosures Commissioner’s recently published 2025 Annual Report highlights a significant increase in reports of alleged wrongdoing, with 411 reports received in 2025 compared with 262 in 2024, an increase of 57%. The Commissioner also notes an increase in reports from the private sector, although these remain in the minority.

Promoting a Culture of Speaking Up

This upward trend is a reminder that protected disclosures are likely to become an increasingly familiar route for Employees seeking to raise concerns about workplace wrongdoing. Private sector Organisations with 50 or more Employees are required to maintain internal reporting channels, and the Commissioner emphasises the importance of Organisations properly following up on reports and promoting a culture of accountability and speaking up. The Commissioner also took the opportunity to encourage smaller Organisations to promote a culture of speaking up in the workplace by putting in place appropriate reporting procedures.

AI Augmented Reports

The Report also highlights the increasing use of AI tools by reporting persons to prepare their disclosures. The Commissioner notes that these reports are often longer and more voluminous, containing significant amounts of information that may not be directly relevant to the alleged wrongdoing, which has increased the time required to identify the core issues. This trend is likely to present a similar challenge for Employers, who may increasingly need to assess lengthy, AI-assisted reports and distinguish the substantive concerns from extraneous material.

What this means for Organisations?

Overall, the Report reinforces the need for Organisations to be prepared. As Employees become increasingly familiar with the protected disclosures framework, Organisations should expect more concerns to be raised through formal channels and should ensure that they have the systems, procedures and capability to manage those concerns effectively.

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