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The EU Whistleblowing Directive

The Whistleblower Directive (EU 2019/1937) brings important requirements for companies with at least 250 employees. As of 17 December 2021, these companies have to implement a reporting system.

The Whistleblower Directive (EU 2019/1937) requires companies with 250 or more employees to implement a reporting system as of 17 December 2021.

In this whistleblowing info corner, you will find regular legal updates on national guidelines within the CEE region, information about upcoming events, a general assessment of the EU Whistleblowing Directive and a short introduction to our All-in-One Whistleblowing Solution.


Touchpoints: labour law, data protection

Beneath the surface of the Whistleblower Directive are complex topic blocks that you will need to consider in the future:

  • Does the introduction of a reporting channel require separate agreements under labour law?
  • Company agreements:
    • insofar as control measures affect human dignity
    • automated personnel data systems, systems for the assessment of employees, etc.
    • general rules of order, company suggestion and complaint system, etc.
  • What applies if the works council refuses to conclude a works agreement?
  • Substitution of consent by conciliation body possible?
  • Is it necessary to conclude individual agreements?
  • Legal basis for processing: legal obligation | overriding legitimate interests.
  • Adaptation of the data protection declaration, the procedure directory and the deletion concept.
  • Assumption for AT (according to the German Conference of Independent Data Protection Authorities): data protection impact assessment.
  • Conclusion of a data processing agreement, conclusion of standard contractual clauses, intra-group data transfer agreements, etc.
  • Balancing of interests: Duty to inform/duty to disclose to accused vs. preservation of confidentiality of whistleblowers.
  • Postponement of the duty to provide information if this would jeopardise investigations or if legal provisions prevent disclosure.

local whistleblowing updates

Find more local legal updates and information in our country-specific whistleblowing pages:

Read through our recent legal updates on whistleblowing within the CEE region and find more information about related upcoming events.

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publications & events

media coverage

23 November 2021



Whistleblower: Warum Unternehmen nicht auf das Gesetz warten sollten

This article was published in Die Presse, on 22 November 2021.

Hinweisgebern muss ermöglicht werden, Missstände aufzudecken. Schon jetzt Vertrauen in interne Systeme zu schaffen, ist vorteilhaft.


Whistleblowing: what new duties will arise for employers? | Czech Republic

The Chamber of Deputies is currently discussing at first reading a bill on the protection of whistleblowers. This act should implement the European directive on whistleblowing1, and should therefore become effective within the implementation period, i.e. no later than 17 December 2021.

media coverage

02 December 2019


M.Roibu M.Moga-Paler

Protecția avertizorilor (whistleblowers), sarcina companiilor. Cât timp avem pentru a ne conforma

Find the original article here

O nouă Directivă europeană, care va trebui să fie transpusă și în România, prevede obligația pentru anumite companii de a crea canale interne prin care angajații lor (și nu numai) să poată raporta încălcări ale legislației UE.


29 August 2019

czech republic

New developments in the Czech competition authority's decision-making practice: whistleblowers and appointed guardians

The Czech Office for the Protection of Competition recently found two companies guilty of bid rigging in a public tender.


New regulation on whistleblowing in the Czech Republic


02 May 2019



Increased and uniform protection is coming: EU adopts new rules protecting and encouraging whistleblowing

Scandals from Danske Bank to LuxLeaks and the Panama Papers would never have come to light were it not for insiders who dared to expose major wrongdoings within companies and organisations.

press release

19 October 2017



Schoenherr launches comparative internal investigations primer in CEE

Schoenherr has launched its comparative legal guide for internal investigations across ten jurisdictions in Central and Eastern Europe. 


Schoenherr has developed an all-in-one solution for the Whistleblowing Directive: As a one-stop-shop, Schoenherr takes over the entire process, from the tip of the iceberg to the very bottom: legal advice, support with technical implementation, organisation of an ombudsperson as well as implementation in your company. 

All-in-One Solution: learn more


If you have any questions about the Whistleblowing Directive, or Schoenherr's All-in-One Whistleblowing Solution, please feel free to contact us!

Austria & CEE



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General Counsel, Compliance Officer

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Czech Republic


Attorney at Law

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