First published in April 2025, the guidance sets out the SFO's approach to assessing corporate co-operation when making decisions on criminal prosecution. In particular, it provides for the possibility of entering into a Deferred Prosecution Agreement (DPA) if a company promptly self-reports suspected wrongdoing and fully co-operates with the investigation. Where these conditions are met, the SFO commits to inviting the company to negotiate a DPA, unless exceptional circumstances apply.

The guidance, updated on 13 October 2026, introduces an additional opportunity for companies to discuss potential reports of corruption and other serious corporate offending directly with senior SFO officials before making a formal disclosure.

Previously, companies could discuss the self-reporting process with representatives of the SFO's Intelligence Division. Under the updated guidance, their legal representatives can now contact the SFO's General Counsel directly to discuss a potential self-report before formally submitting it. Companies may remain anonymous at this stage.

During these preliminary discussions, the parties may consider the circumstances of the suspected wrongdoing and whether the matter falls within the SFO's jurisdiction. A dedicated communication channel has been established for such enquiries. Formal corporate self-reports must still be submitted to the SFO's Intelligence Division.

The updated guidance also clarifies that companies should adopt a risk-based and proportionate approach when establishing the full extent of suspected criminal conduct. In addition, it specifies when the six-month period within which the SFO aims to conclude DPA negotiations begins: the period now runs from the company's acceptance of an invitation to enter into negotiations, rather than from the date the invitation is issued.

The SFO stated that the changes were developed in response to feedback from the legal community and are intended to make engagement with the agency easier for companies considering voluntary self-reporting.