Corruption and institutional integrity
On paper, Britain has just rebuilt its defences against corruption: a new national strategy, a new ethics commission, a register for barring bad suppliers from public contracts. Look closer. The register is empty, the commission can only advise, and breaking the revolving-door rules still carries no legal penalty at all.
Most gaps here are half-built machines waiting for teeth: lobbying registers that miss most lobbyists, watchdogs on goodwill budgets, whistleblowers protected only after the damage. A few need no permission at all: a fraud-spotting unit for procurement data, a defence fund for small newsrooms, an archive nobody can quietly edit.
Full landscape notes (July 2026)
After three years without one, the UK published a new Anti-Corruption Strategy in December 2025 (123 commitments across three pillars) and appointed Baroness Margaret Hodge as Anti-Corruption Champion, with a Countering Illicit Finance Summit planned for 2026. The institutional map has been redrawn: the Ethics and Integrity Commission launched in October 2025 (replacing the Committee on Standards in Public Life), and ACOBA was closed, its revolving-door functions split between the Independent Adviser on Ministerial Standards and the Civil Service Commission. The Procurement Act's debarment regime went live in February 2025, but the register remains blank and the first investigations (Grenfell-linked cladding suppliers) were paused at prosecutors' request. ECCTA implementation is advancing (identity verification mandatory for new directors since November 2025, 3.8m verification codes issued), and in June 2026 HM Treasury confirmed the FCA will become the single AML supervisor for professional services, though implementation will take years. The Representation of the People Bill (February 2026) restores Electoral Commission independence by repealing the strategy-and-policy-statement power and raises maximum fines from £20,000 to £500,000, but leaves donation size uncapped. The first anti-SLAPP strike-out (Kamal v Tax Policy Associates, March 2026) proved the ECCTA provisions work, but only for economic-crime speech. FOI is under strain: record request volumes (94,526 in 2025), a 41% real-terms cut to ICO FOI funding over a decade, and 2026 ministerial exploration of lowering the section 12 cost ceiling. Enforcement agencies remain under-resourced relative to caseloads.
The gaps (19)
A debarment register with no entries and no independent trigger
Britain built a blacklist for dodgy government contractors. It has zero entries.
Statutory lobbying register still excludes in-house lobbyists
Most lobbyists never appear on the lobbying register. The law only counts consultants.
Revolving-door rules without legal sanctions after ACOBA's closure
For most officials, breaking the revolving-door rules risks nothing but embarrassment.
Ethics and Integrity Commission lacks statutory footing and investigative powers
The new ethics watchdog answers to the Prime Minister it is meant to watch.
Donation caps and real source-of-funds checks missing from party-finance reform
A single donor can still give a British political party an unlimited sum. Legally.
No sustainable funding model for economic-crime enforcement
Fraud enforcement pays for itself three times over. Britain still starves it.
Weakly supervised verification agents and unreformed limited partnerships at Companies House
Company ID checks now exist. The agents doing the checking are barely supervised.
Overseas territories' beneficial-ownership registers closed to public scrutiny
Half the shell companies in major leaks fly the British flag. Their owners stay hidden.
FOI enforcement starved while ministers explore narrowing the Act
Freedom of information requests hit a record high. The watchdog's budget fell 41%.
Anti-SLAPP protection stops at economic crime
Courts can now throw out bullying libel suits, but only ones about economic crime.
No Office of the Whistleblower
Whistleblowers catch more fraud than auditors. UK law protects them after the sacking.
No charitable pathway or endowment for investigative journalism
265 local papers gone, and journalism still doesn't count as a charitable purpose.
Parliament passes law it never checks: no working post-legislative or SI scrutiny system
Parliament passes laws by the shelf-load. It almost never checks whether they worked.
Think-tank ecosystem: no funding disclosure requirement and no regional policy capacity
Think tanks help write government policy. They never have to say who pays them.
No tamper-evident public archive infrastructure for evidence-grade records
Corrupted records convicted hundreds. Destroyed records stripped citizens of status.
No running register of the contracts government hands out without competition
Government's no-competition contracts are all public. Nobody adds them up.
No way to see when someone helps write the rules they are later paid under
A firm helped design the levy it's now paid from. The records don't talk to each other.
No one checks whether the state could ever leave its biggest software suppliers
Government signs software deals it can't leave, and never checks that it could.
No human-rights due-diligence standard in public technology procurement
Public money buys technology with no duty to check suppliers' human-rights records.
Who is already here: key actors (15)
- Transparency International UK (charity): Research and advocacy on political integrity; published the November 2025 post-legislative review of the Lobbying Act and monitors overseas-territories register access.
- Spotlight on Corruption (charity): Tracks UK enforcement bodies (SFO, NCA, FIU) and legislation; published the definitive seven-gap critique of the Representation of the People Bill.
- UK Anti-Corruption Coalition (network): Coalition of anti-corruption NGOs; its December 2025 response identified lobbying, whistleblowing and MoD economic crime as the strategy's missing pieces.
- Joint Anti-Corruption Unit (Home Office) (government body): Owns the UK Anti-Corruption Strategy 2025 and coordination of its 123 commitments across departments.
- Ethics and Integrity Commission (government advisory body): Launched 13 October 2025 replacing CSPL; advisory only, cannot investigate individual cases, all members appointed by the PM.
- Companies House (government body): Implementing ECCTA: identity verification mandatory since 18 November 2025; limited-partnership reforms and enforcement phase due through 2026.
- Serious Fraud Office (government body): Prosecutes top-tier fraud and bribery; returned £3 per £1 of budget 2019-24 yet salaries lag the private sector it investigates.
- National Crime Agency (government body): Houses the NECC, International Corruption Unit, IACCC and UKFIU; chronic underfunding documented by Spotlight and FATF (FIU still below 200 staff).
- Electoral Commission (regulator): Political finance regulator; RPB Bill would restore its independence and raise its maximum fine from £20,000 to £500,000.
- Debarment Review Service (Government Commercial Agency) (government body): Runs Procurement Act debarment investigations since the Procurement Review Unit was absorbed in April 2026; the public list is still blank.
- mySociety (charity): Runs WhatDoTheyKnow; its 2026 report warned FOI is 'sliding into obsolescence' and proposed extension to private providers of public services.
- The Bureau of Investigative Journalism (nonprofit newsroom): Investigates illicit finance and corruption; documented the landmark March 2026 anti-SLAPP strike-out.
- Finance Uncovered (nonprofit): Trains and supports journalists worldwide on illicit-finance investigations from a small UK base reliant on philanthropy.
- Public Interest News Foundation (charity): The UK's only charity dedicated to regenerating local public-interest news; a fraction of the scale the sector's decline demands.
- UK Anti-SLAPP Coalition (network): Drafted a model anti-SLAPP law; campaigns to extend protection beyond the economic-crime-only ECCTA provisions.
Funders active or plausible here (12)
- Joseph Rowntree Charitable Trust
- Joseph Rowntree Reform Trust
- Luminate
- Open Society Foundations
- Oak Foundation
- Sigrid Rausing Trust
- David and Elaine Potter Foundation
- FCDO (international anti-corruption programmes, IACCC)
- Home Office / Joint Anti-Corruption Unit (strategy implementation funding)
- Economic Crime Levy and Asset Recovery Incentivisation Scheme proceeds (potential ringfenced enforcement funding)
- Nuffield Foundation (justice and governance research)
- Public Interest News Foundation (pooled philanthropic funds for journalism)
Policy notes
The UK Anti-Corruption Strategy 2025 (December 2025) is the organising document (123 commitments, three pillars, oversight involving civil society and Parliament), but several commitments lack timelines, per the UK Anti-Corruption Coalition. The Representation of the People Bill (February 2026) carries political-finance reform: Electoral Commission independence restored (strategy-and-policy statement repealed), fines raised to £500,000, Know Your Donor checks, £100k overseas-elector cap and crypto moratorium via Rycroft Review amendments. ECCTA continues phased commencement (limited-partnership reform from spring 2026; IDV enforcement late 2026); in June 2026 the FCA was confirmed as future single AML supervisor, implementation taking years. Holes: no lobbying commitment anywhere in the strategy; whistleblowing deferred to 'explore by 2027'; no MoD economic-crime measures; SLAPP protection confined to economic crime; FOI facing a section 12 cost-ceiling reduction rather than reform; overseas territories conceded legitimate-interest-only registers; debarment has no independent trigger and no entries.