Where do you need an internal whistleblowing channel?

• EUEuropean Union (overview)Mandated· Via national transpositionThe EU Whistleblower Directive sets a floor that each of the 27 Member States implements in its own law. Headcount, sector and public-body rules vary nationally.Europe
• PLPolandMandatedPoland transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• DEGermanyMandatedGermany transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• IEIrelandMandatedIreland transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• FRFranceMandatedFrance transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• ITItalyMandatedItaly requires internal channels for private entities with 50+ employees, and also for smaller entities that have adopted a 231 organisational model.Europe
• ESSpainMandatedSpain transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• NLNetherlandsMandatedNetherlands transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• DKDenmarkMandatedDenmark transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• LULuxembourgMandatedLuxembourg transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• SESwedenMandatedSweden transposes the EU Whistleblower Directive: private employers with 50 or more workers must run internal reporting channels.Europe
• NONorway (EEA)Mandated· Low thresholdNorway is not bound by the EU Directive but its Working Environment Act requires written internal whistleblowing routines from 5 regularly employed staff.Europe
• CHSwitzerlandNo mandateNo general federal duty for private employers to run internal channels. Parliament rejected the Code of Obligations whistleblowing revision in 2020.Europe
• GBUnited KingdomSectoralWorkers are protected under PIDA, but there is no universal duty for employers to run a whistleblowing channel. Certain FCA/PRA-regulated firms must.Europe
• JPJapanMandated· Size-basedEmployers with more than 300 workers must set up a whistleblowing system and designate responsible staff. Employers with 300 or fewer have a best-efforts duty.Asia-Pacific
• SGSingaporeSectoral· Listed issuersSGX-listed issuers must state in their annual report that a whistleblowing policy is in place and explain how they meet related requirements.Asia-Pacific
• HKHong Kong SARSectoral· Comply or explainHKEX-listed issuers should establish a whistleblowing policy and system. This is a Corporate Governance Code provision on a comply-or-explain basis — not a mandatory listing rule.Asia-Pacific
• AUAustraliaSectoral· Policy mandateCertain companies must have a whistleblower policy under the Corporations Act. This is a policy requirement for specific entity types — not a universal hotline duty for all employers.Asia-Pacific
• NZNew ZealandPublic sectorPublic sector organisations must have internal procedures. Private employers are encouraged to have them but are not generally required to.Asia-Pacific
• USUnited StatesSectoralNo employer-wide federal duty to run a whistleblowing system. Listed companies' audit committees must have procedures for complaints about accounting and auditing matters.Americas
• CACanadaSectoral· BanksBanks and authorized foreign banks must have whistleblowing policies and procedures under the Bank Act. This is not a duty on every federally regulated financial institution or private employer.Americas
• BRBrazilSectoral· Procurement / integrityIntegrity programmes with reporting channels are expected in defined public-procurement situations. This is not a blanket obligation on every bidder or employer.Americas
• DIFCUAE — DIFCSectoral· Free zoneIn the Dubai International Financial Centre, DFSA-regulated firms are expected to maintain whistleblowing arrangements under DFSA rules. Treat as separate from ADGM.Middle East
• ADGMUAE — ADGMMandated· All registered entitiesSince 31 May 2025 all ADGM registered entities must have proportionate, effective whistleblowing arrangements. Some categories also need written policies.Middle East

This map focuses on duties to run internal channels. Many jurisdictions also have external reporting authorities and anti-retaliation protections even where internal systems are not mandatory.