In December 2019, the Directive on the protection of persons who report breaches of Union law (“Whistleblowing Directive“) entered into force. Member States are required to transpose the Whistleblowing Directive into national laws (“National Implementation Acts“) and to apply such National Implementation Acts as of 17 December 2021. The National Implementation Acts will have to require companies with more than 50 employees to implement internal compliance reporting channels and to provide protection for certain whistleblowers (i.e., protection against retaliation).

Companies already having an internal whistleblowing system may need to make changes to such system depending on how anonymous reporting is handled, on permissible subject matters and on internal responsibilities. Details will, however, depend on the respective National Implementation Acts.

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