WeMoral Report Finds Five Models of Whistleblower Supervision Across the EU

Supervision of workplace whistleblowing rules takes five different forms across the European Union. Seven member states created a dedicated authority that can issue fines, five split the task between several bodies, and one supervises without any power to fine. Two designate a supervisor in principle without naming it in the act, and twelve named no supervisor at all. The counts come from a comparison of all 27 national transpositions of Directive 2019/1937, published today by WeMoral, a whistleblowing software company. The report is free and requires no registration: https://wemoral.com/reports/eu-whistleblower-transposition/wemoral-report-2026

Directive 2019/1937 set a common floor for whistleblower protection and gave member states until 17 December 2021 to put it into national law. WeMoral compiled the comparison from the primary legislation of each member state, and every figure cites the article it came from. The report runs to 46 pages and records 33 data points per country across 7 charts and 18 tables.

The route into national law varied as well. Twenty member states passed a new dedicated act and six amended legislation that predated the directive. Belgium used a package of eight separate instruments, the first in force in September 2022 and the last in January 2024.

Germany sits in the group that designates a supervisor without naming the body in the statute. Its act caps the fine on a non-compliant organization at 50,000 EUR, and retaliation can reach 500,000 EUR through section 30 of the Administrative Offences Act. Reports are kept for three years from the close of a case, with an option to extend.

Record keeping is where the national rules differ most. Fifteen member states fix a period and twelve set none. Among the fifteen, nine start the clock once the case has been handled, four start it the day the report arrives, and two leave the starting point unstated. Spain permits up to ten years, while Cyprus requires deletion three months after a case closes.

A knowingly false report is handled three ways. Twelve member states impose an administrative fine, nine work through criminal law, and six attach no sanction beyond the loss of protection. Spain sets the highest fine at 300,000 EUR, and Ireland combines up to 100,000 EUR with up to two years in prison.

Anonymous reporting produces the widest spread in the report: eight distinct national positions. Spain and Portugal require employers to accept anonymous reports, as does Belgium above 250 workers. Twelve member states permit them without obliging anyone to take them. Bulgaria, Latvia and Malta bar them or leave them unprotected. Denmark, Estonia and Sweden do not mention them in their acts, and France addresses them only in the financial sector.

"Compliance teams want to know who checks the channel and what happens if nothing is in place," said Marta Giemza, corporate ethics expert at WeMoral. "In seven member states a named authority can fine an employer for it. In twelve there is nobody to ask, and the question surfaces only once a report has already gone wrong."

The report is a comparative analysis of published legislation and is not legal advice. Editions are published in English, German, Polish, Spanish and French.

Video walkthrough of the findings: https://www.youtube.com/watch?v=SikwNqhW6E4

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Press contact: Marta Giemza, corporate ethics expert
press@wemoral.com
+48 574 139 632
https://wemoral.com

WeMoral is whistleblowing software with anonymous reporting, encryption at rest and in transit, and data that never leaves the EU. It helps organizations receive, investigate and resolve reports of misconduct through one secure channel, in line with the EU Whistleblower Directive and GDPR. Reporting is available in 25 languages, and a channel can be running in five minutes. WeMoral helps organizations act on problems while those problems are still small, and protect the people who raise them. More at https://wemoral.com/whistleblowing-software

This release was published on openPR.