Author: Mr Adrian Ramdat (Director of Training & Consultancy)
May 2026
The publication of the Fisher Review into disclosure and fraud offences is one of the most significant examinations of disclosure practice in recent years. Led by Jonathan Fisher KC and published by the Home Office on 20 March 2025, the review, formally titled Disclosure in the Digital Age, examines whether the current disclosure regime remains fit for purpose in an era where almost every investigation involves vast quantities of digital material.
Its conclusion is clear. The legal framework is not fundamentally broken, but the way disclosure is being applied operationally is increasingly under strain. The report sets out 45 recommendations and identifies systemic weaknesses in capability, culture, leadership, digital competence and training that, if left unresolved, risk miscarriages of justice, collapsed trials and further erosion of public confidence. For investigators, disclosure officers, prosecutors and training providers alike, this is not simply another procedural review. It signals a major shift towards the professionalisation of disclosure as a specialist discipline.
The Scale of the Problem
The sheer volume of digital material now encountered in criminal investigations is one of the review's strongest themes. Mobile phone downloads, social media records, cloud storage, CCTV, body worn video and financial datasets have transformed disclosure from a largely paper-based exercise into a technologically complex process requiring specialist skills. The review references investigations involving millions of documents and terabytes of data, and makes clear that the pressure extends well beyond fraud, with serious violence, sexual offences and organised crime all affected.
The report rejects the idea that disclosure failures are isolated incidents. It describes recurring systemic weaknesses: poor scheduling, inconsistent decision-making, weak supervision, inadequate recording of rationale and ineffective communication between investigators and prosecutors. None of this will surprise practitioners working in the field. These are issues that arise regularly in operational reviews and training environments, and the review's value lies partly in formally articulating what many have been saying for years.
The wider context matters too. This is the first independent review of the disclosure regime since the Roskill Report in 1986. That nearly forty years passed before such a review took place arguably reflects the same cultural undervaluation the report sets out to address.
Training and Capability
The inconsistency of disclosure training across policing and investigative agencies is perhaps the most significant operational finding. Some officers receive detailed, practical classroom-based training; others receive only limited online packages or learn informally on the job. The result is predictable: uneven standards, uncertainty around legal obligations and heightened risk of error.
The review is particularly critical of disclosure responsibilities being handed to inexperienced staff without adequate supervision, a problem compounded by the growing complexity of digital evidence and technology-assisted review tools.
The report recommends nationally standardised disclosure learning frameworks built around Bronze, Silver and Gold standards, covering foundational training for all investigators, specialist pathways for disclosure officers, and advanced accreditation for senior practitioners managing complex cases. Mandatory refresher training is also proposed, recognising that the law, technology and investigative practice continue to evolve rapidly.
Technology and AI
The report is unambiguous that traditional manual review is no longer sustainable. Mr. Fisher KC states directly that it is unreasonable and impracticable to expect investigators to manually review every item of digital material within a reasonable timeframe. The review supports AI-assisted review tools, smart search, automated categorisation and digital disclosure platforms, and recommends a Cross-Agency AI Disclosure Protocol to ensure consistent application across law enforcement.
At the same time, the report is clear-eyed about the risks. Poorly configured systems, weak governance or undertrained operators could create disclosure failures just as easily as the problems they are meant to solve. Technology must support professional judgement, not replace it. Agencies that invest heavily in new tools without matching investment in training and competence may find the risks shift rather than reduce.
The Push Towards Professionalisation
Running through the entire review is a single, consistent argument: disclosure can no longer be treated as a secondary administrative function. It is a specialist investigative discipline, and it needs to be treated as one, with formal learning pathways, recognised competencies, quality assurance frameworks, supervision standards and leadership accountability.
The Bronze, Silver and Gold framework and the proposed accredited senior disclosure officer pathways reflect this directly. For many organisations, the cultural shift required will be substantial. Disclosure expertise may soon carry the same professional expectations as digital forensics, intelligence analysis or financial investigation.
Where Implementation May Struggle
Several of the 45 recommendations are likely to generate debate. The proposed role of the College of Policing in quality assuring disclosure learning is one. Recommendation 18 calls for more stringent QA of training delivered by the College itself, by Higher Education Institutions and by other delivery partners, with results shared with the National Police Chiefs' Council. The College is already piloting supportive on-site audits, but the structural difficulty remains: the College is being asked to quality assure its own training provision alongside that of competing providers. How genuine independence is maintained within that model is not fully explained, and will likely attract scrutiny.
Resources are the other major concern. The recommendations require real investment in training, specialist staff, technology, supervision structures and accreditation. At a time when investigative workloads are high and budgets are stretched, the risk is that organisations endorse the principles whilst struggling to deliver them in practice. The "postcode lottery" of disclosure capability that the review criticises will not be resolved without sustained, consistent funding across forces and agencies.
A Warning That Can´t Be Ignored
The Fisher Review is ultimately a warning that disclosure cannot continue to operate on models designed for a pre-digital era. The volume of modern investigative material, combined with legal complexity and rapid technological change, demands something different, and the report is explicit that future success depends on properly trained professionals who understand both the legal and operational realities of what disclosure actually involves.
The direction of travel is clear: greater accountability, higher professional standards and far more rigorous expectations around competence. Disclosure capability can no longer rest on informal learning, inconsistency or theoretical understanding alone. Investigators and disclosure practitioners need to be able to apply their obligations confidently within the reality of modern investigations, and they need the training, supervision and quality assurance structures to back that up.
At The Signature Brand Training & Consultancy, our disclosure training has long focused on the issues the Fisher Review identifies, including poor scheduling practices, weak rationale recording, inconsistent decision-making, supervision challenges and the difficulties created by large volumes of digital material. Our programmes are quality assured and built around operational reality, using practical examples, case discussion and real-world investigative challenges rather than legal theory in isolation.
Alongside full disclosure programmes, our bitesize sessions provide focused, practical learning that can be delivered flexibly to investigators, supervisors and disclosure officers working in an increasingly demanding environment.
Contact us at info@thesignaturebrand.co.uk to find out how we can support your disclosure capability.
Photo by Agence Olloweb on Unsplash