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Friday, April 10, 2026

One step closer to mandatory whistleblower systems in Germany - JD Supra

Following Germany's initial attempt last year to implement the EU Whistleblower Directive (Directive (EU) 2019/1937), aimed at ensuring harmonized and improved protection of whistleblowers throughout Europe, the Federal Ministry of Justice has now published a draft bill of a Whistleblower Protection Act (Hinweisgeberschutzgesetz). As the deadline for transposing the EU Whistleblower Directive 2019/1937 into national law expired in vain on 17 December 2021, a swift adoption and implementation of the act is expected. As of now, there will be no transitional arrangements for companies with 250 or more employees. Likewise, most other European countries have already passed similar national laws or are about to do so very shortly.

1. Obligation to set up reporting systems

According to the current draft bill, companies with more than 49 employees are obliged to set up reporting systems or adapt an existing reporting systems to meet the new requirements. Companies with up to 249 employees are to be granted a grace period until December 2023. Companies in "sensitive" sectors will have to set up a reporting office, regardless of the number of employees they have (this applies inter alia to entities providing investment services and asset management companies). In some areas, such as financial regulatory law, there are already a number of sector-specific requirements, some of which are of higher priority, that require the establishment of a reporting office in principle, but do not...



Read Full Story: https://www.jdsupra.com/legalnews/one-step-closer-to-mandatory-6033408/