The SFO publishes its 2025-26 Annual Report

On 16 July 2026, the Serious Fraud Office ("SFO") published its Annual Report and Accounts for 2025-26 (the "Annual Report"), providing an overview of the SFO's performance, strategic objectives and financial activities over the year from 1 April 2025 to 31 March 2026. 

The Annual Report marks the second year in the SFO's five-year strategy (2024-2029) and its first following the retirement in January 2026 of the former director, Nick Ephgrave, who has been succeeded by Graham McNulty QPM, currently acting as interim director.

Overview

According to the Annual Report, the SFO has an active caseload of around 120 cases, which includes civil recovery, proceeds of crime and international assistance cases as well as c.40 criminal cases (up from 35 in the previous period). Its annual budget for the period 2025-26 was £107.45m, and it employed 611 permanent, fixed term and backfill temporary officers. 

In terms of performance, the SFO announced five new cases, closed one case, and charged ten suspects, with trial preparations continuing for cases scheduled to be heard in court up to 2028. It conducted seven searches across 24 premises and arrested 14 individuals.  The total value of criminal property recovered (£2.98m) slightly more than doubled from that of the previous year. 

Key highlights reported in the Annual Report:

• In April 2025, the SFO published new corporate cooperation guidance setting out what corporates can expect if they self-report suspected wrongdoing and co-operate fully with investigators. The guidance confirms that, unless exceptional circumstances apply, corporates that self-report suspected wrongdoing and cooperate fully will be invited to negotiate a DPA rather than face prosecution (discussed in further detail in our previous post available here).  
• The SFO charged a director of UK-based aircraft parts trader AOG Technics with fraudulent trading, resulting in conviction following a guilty plea. He was sentenced to four years and eight months in prison for fraud in relation to the global supply of aircraft engine parts, which put public safety at risk and caused widespread disruption to the aviation industry.
• Three former directors of Ethical Forestry Limited entered guilty pleas following an investigation by the SFO investigation into a £70m investment scheme fraud.
• £1.1m was recovered from the sale of a Lake District property in an investigation involving the SFO’s first use of an Unexplained Wealth Order, against the ex-wife of a convicted fraudster (see our previous post for further detail). 
• In July 2025, the SFO used, for the first time, its new powers to freeze cryptocurrency which were introduced by the Economic Crime and Corporate Transparency Act 2023 ("ECCTA 2023"), by obtaining a Crypto Wallet Freezing Order in relation to an ongoing investigation into collapsed outside broadcast company, Arena TV. 
• In December 2025, a £928,479 confiscation order was secured against a convicted fraudster currently serving an eight-year prison sentence following his conviction in May 2024, with the money to be returned to victims.
• The SFO also recovered and returned more than £400,000 to nine victims of a global email fraud scheme orchestrated by a former director of a retail bank, almost 24 years after the offending occurred, in a novel use of the civil recovery regime whereby the SFO paid monies directly to victims (rather than the Treasury).
• The SFO has trained its staff in preparing for the new failure to prevent fraud offence under ECCTA 2023, which came into force in September 2025 and was supported by the SFO. Under the new offence, large organisations can now be held criminally liable if an employee, agent, subsidiary or other associated person commits a relevant fraud offence intending to benefit the organisation and the organisation failed to have reasonable procedures in place to prevent this. (See our previous post for further detail).

Technology and AI

The SFO, as part of a review of current and former e-Discovery software and its wider post-conviction disclosure obligations towards defendants, identified and subsequently reviewed 66 historic conviction cases, which used its legacy e-Discovery platform, Autonomy, and which raised concerns about potential disclosure failings. Following completion of this review in March 2026, the SFO announced that it had found no material that cast doubt on the safety of any past conviction. A subsequent issue was identified in November 2025 and a review of the approximately 20 cases potentially impacted by this remains on-going. 

The SFO's five-year strategy reflects its commitment to using technology to allow employees to deliver work faster and more efficiently. The SFO states that it “scoped opportunities for enhancing data fusion with our intelligence activities” and used “Technology Assisted Review”, although the Annual Report provides few details of what this entails. An AI Steering Group has been established to explore new opportunities and increase AI capabilities.  

The Chief Investigator's Office expanded its remit at the start of 2025-26, taking on responsibility for the e-Discovery team, digital forensics unit, graphics team and reprographics unit. This is anticipated to free up capacity in the Information Technology division to focus on new AI opportunities.

Following the procurement of its first case management system at the end of the previous financial year, the Annual Report indicates that the SFO spent 2025-26 working across teams to further improve the system. The system has been “carefully designed to handle the scale and complexity” of its work and is due to be rolled out to all users in the 2026-27 period.

Future plans

In 2026-27, the SFO's attention will remain on the ambitions set out in its five-year strategy (see our previous post on the strategy here). The SFO will also move to new premises in Canary Wharf before the end of 2026.

Commentary 

The Annual Report reflects another year of operational activity and consolidation for the SFO, as it continues to pursue its five-year strategy. 

Although no DPAs were concluded during the reporting period, the SFO announced in late April 2026 that a judge had approved a DPA with Ultra Electronics Holdings Ltd ("Ultra"), requiring the company to pay a financial penalty of around £10m (plus investigation costs) for bribery offences. The Ultra DPA was the first in five years (see our blog post here). It remains to be seen whether the new cooperation guidance, which builds on earlier versions, will result in further corporates self-reporting suspected wrongdoing, as Ultra had done, and, ultimately, in more DPAs in the coming year.

On AI and other technologies, the Annual Report provides only a high-level overview. The SFO announced the establishment of an AI Steering Group and that it is exploring new AI opportunities. Further details on what AI tools are being used, for what purposes, and what steps are being taken to mitigate against any risks of bias in its decision-making remain to be seen.