EU Whistleblowing Directive

Directive (EU) 2019/1937 sets the rules for internal reporting channels across the EU. Each member state turns it into its own law; in Germany that is the HinSchG. This page is a summary, not legal advice.

Who must have a channel

Member states may go further than these minimums.

Article Rule
Art. 8(3) Private employers with 50 or more workers.
Art. 8(4) Firms under the Annex acts on financial services and money laundering, transport safety and the environment, at any size.
Art. 8(9) Every public-sector body, including entities it owns or controls. States may exempt municipalities with fewer than 10,000 inhabitants or 50 workers, and other public bodies with fewer than 50 workers.
Art. 8(6) Private employers with 50 to 249 workers may share the receipt and investigation of reports. Confidentiality, feedback and the remedy stay with each of them.
Art. 8(7) After a risk assessment, states may oblige smaller private employers too.
Art. 26(2) For private employers with 50 to 249 workers, national law had to apply the duty by 17 December 2023.

Requirement by requirement

The binding text is on EUR-Lex.

Requirement Article OpenWhistle Shown in
Internal channel from 50 workers Art. 8(3) The channel, on your own server Install
Reports in writing or orally Art. 9(2) The web form; a guide for a telephone channel Whistleblower guide, Telephone channel
Confidential identity Art. 9(1)(a), Art. 16 Confidential mode; the identity shown only to the case handler (while unassigned, an admin of the case's organisation), with an audited reason Managing reports
Acknowledge within 7 days Art. 9(1)(b) The 7-day deadline on dashboard, case and status page Deadline tracking
An impartial person or department Art. 9(1)(c) not covered: you appoint them; roles limit who sees a case Roles
Diligent follow-up Art. 9(1)(d) not covered: you take the follow-up; the case page records it Managing reports
Feedback within 3 months Art. 9(1)(f) The 3-month deadline; replies through the anonymous channel Deadline tracking
Information on reporting externally Art. 9(1)(g) not covered: the organisation publishes it —
Record keeping Art. 18 Every report and message stored, encrypted; PDF export. The audit log records admin actions Managing reports, Audit log
Personal data and deletion Art. 17 Retention; four-eyes deletion Data retention, Managing reports
Anonymous reports Art. 6(2), left to member states Anonymous mode; no IP address stored Anonymity layers