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Whistleblowing – implementation necessary


by Maciej Ogórek

23 November 2021


The draft bill on the protection of persons reporting breaches of law is at an advanced stage of the legislative process. EU laws require that measures to protect whistleblowers be implemented by 17 December 2021. Therefore, the bill may be adopted still this year.


The bill requires employers to introduce internal rules for notifying the employer of infringements noticed by employees (or contractors). The rules should ensure, among other things, that a notification is accepted and examined by a designated person, protection of the whistleblower's identity, and protection against retaliatory action from the employer.


Whistleblowing at smaller employers too


The relevant procedures must be implemented in entities that hire at least 50 people (including temporary workers), and also by employers who are covered by acts listed in an annex to the Directive (regardless of the headcount). These include mainly entities in the business of:


  • financial services, products and markets;
  • counteracting money laundering and terrorist financing;
  • transport security;
  • environmental protection.


The draft says that the new law will enter into force only 14 days after its promulgation.


Deadlines for implementation of whistleblowing procedures


Employers who hire at least 250 people will be obliged to implement a whistleblower protection procedure within 14 days. The same deadline will apply to employers covered by the statute because of their line of business.


Other employers, hiring from 50 to 249 people, will have to implement the relevant measures by 17 December 2023.


The bill may still be amended.


If you have any doubts about the implementation of a system to protect whistleblowers in your company, please 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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