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Friday, April 24, 2026

An Overview of the Implementation of the Whistleblowing Directive ... - Lexology

Part 2: The status of implementation

The objective of this three-part article series is to analyse how the Nordic countries are implementing the new Whistleblowing Directive (2019/1937). In the first part we described the requirements of the Whistleblowing Directive. In the first part we described the requirements of the Whistleblowing Directive. In Part 2 of this series, we will look at the current implementation status in Finland, Sweden, Denmark, and Norway. Whereas in some of these countries the law has already been passed, in others it is only at the preparatory stage. We will also discuss some specific points of concerns in the proposed or accepted laws and their suggested solutions as well as look at how the objective to provide channels to report corporate misbehaviour can be reconciled with the protection of personal data. In the third part, we will analyse the laws passed in the countries that are currently lacking behind in the implementation process.

1. Finland

Until now, Finland has not had any general legislation on whistleblowing as such legislation was only implemented in some specific sectors like banking. A working group tasked with preparing the implementation of the directive proposed a new general Whistleblowing Act (" ilmoittajansuojelulaki") to be enacted in 2021. A government proposal to that effect was published on 19th of September 2022. Finland is therefore late with implementing the Whistleblowing Directive as the deadline has already expired...



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