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Does your organization need a whistleblower channel?

National law determines which organisations need an internal reporting channel. The EU directive generally covers private entities with 50 or more workers, with sector-specific rules and public-sector provisions. Check the applicable national law and implementation dates.

Threshold

In Sweden, the internal-channel requirement began on 17 July 2022 for public employers with at least 50 workers and private employers with at least 250. It has applied to private employers with 50–249 workers since 17 December 2023. The Act entered into force on 17 December 2021. Worker numbers are assessed at the start of the calendar year; sector-specific rules may also apply. Other countries have their own national provisions.

Sanctions

In Sweden, the Swedish Work Environment Authority may issue injunctions backed by conditional fines. Obstructing reporting or retaliating against a reporting person can result in damages. The Act does not set a general turnover-based penalty. Other countries determine penalties under their national law.Legal sources: SFS 2021:890, 10 kap. 3–4 §§ · Directive (EU) 2019/1937, Article 23