FCA publishes terms of reference for independent review concerning Mr Andriesz

Notably, the review has been widened beyond the original remit: it will now assess whether the regulator met its statutory whistleblowing responsibilities and followed its own internal policies, including how it dealt with the individual's concerns that he had suffered detriment. The period under scrutiny spans at least 2017 to 2026. Why this matters for compliance teams: although the review examines the regulator's own conduct, it signals heightened supervisory focus on speak-up arrangements and, in particular, on detriment against whistleblowers.

Firms should expect the findings and recommendations to inform supervisory expectations and potential future guidance. The explicit reference to vulnerable individuals reinforces the link between whistleblowing handling and the treatment of customers and staff in vulnerable circumstances. Recommended actions: (1) Re-test your whistleblowing framework against SYSC and PIDA obligations, including confidentiality, triage, escalation and record-keeping; (2) evidence how detriment allegations from reporters are identified, investigated and escalated to the board or a designated NED champion; (3) confirm vulnerable-individual policies capture whistleblowers as well as customers; (4) review MI on case volumes, timeliness and outcomes ahead of likely supervisory questioning; (5) brief the board and audit committee on the review's scope and likely thematic read-across.

This is a forward-looking governance agenda item rather than an immediate compliance deadline, but early preparation reduces remediation and conduct-risk exposure.