Workers who report wrongdoing face different remedies for retaliation and dismissal across the EU, despite legislation intended to establish a common minimum level of protection.

A worker dismissed after blowing the whistle may be entitled to reinstatement in one EU country while having no specific civil remedy in another, according to a new report which compares how the bloc’s 27 member states have implemented the EU Whistleblower Directive.

The 2026 Report on Whistleblower Directive Transposition Across the EU from whistleblowing software company WeMoral found that, although every member state prohibits retaliation against whistleblowers, national laws differ substantially over what happens when that prohibition is breached.

Directive (EU) 2019/1937 was intended to establish minimum protections for people reporting breaches of EU law. Organisations with 50 or more workers must generally operate an internal reporting channel, protect a reporter’s identity and observe deadlines for acknowledging and responding to reports. The directive also requires protection against retaliation and provides for the burden of proof to move to the employer once the necessary basis for a retaliation claim has been established.

Different remedies for dismissal

The clearest differences emerge in the remedies available when an employer retaliates against a whistleblower.

WeMoral found that Cyprus and Italy provide some of the strongest protection, allowing retaliatory measures to be declared...

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