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Amended Whistleblowers Act


19 April 2022


The second, completely revised version of the Whistleblower Protection Bill was published on the website of the Polish Government Legislation Centre on 12 April 2022. It has been sent for public consultation. The deadline for the implementation of the EU Directive passed in January this year, so we can expect an accelerated legislative process.
The most important changes to the bill include:

  • extended list of entities obliged to implement an internal whistleblowing procedure – entities employing at least 50 people, including those providing work for a legal entity;
  • extended vacatio legis – companies employing 250 people should adopt an internal procedure within a month from the effective date of the Act. In practice, companies will have 3 months for that as the bill is to become effective after 2 months;
  • an incentive system for whistleblowers which is an absolute novelty. Each entity will be free to decide on the type of incentives and the rules for using them;
  • period of mandatory data retention in the internal register reduced to 12 months;
  • change of sanctions for persons who obstruct whistleblowing activities – a fine or imprisonment;
  • failure to establish an internal procedure or establishing one contrary to the statute is liable to a fine only;
  • extended list of retaliatory actions to include mobbing, discrimination or damage to reputation.


The bill has been sent for public consultation. Rödl & Partner experts will keep you updated on the progress of legislative work and will assist you in implementing relevant internal regulations. If you have any questions about the bill, you are welcome to contact our experts.


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Jarosław Hein

Attorney at law (Poland), Tax adviser (Poland)


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Łukasz Napiórkowski

Attorney at law (Poland)

Associate Partner

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