Greek whistleblower protection law "Νόμος 4990/2022"

Greece protects whistleblowers under Law 4990/2022, the act that brought EU Directive 2019/1937 into national law on 15 November 2022. Outside reports go to the National Transparency Authority. A company that breaks the rules can be fined up to 500,000 euros, and a knowingly false report can land someone in prison. Here is how the law works.

Who does Law 4990/2022 protect?

The law shields anyone who reports a breach of EU law they learn about through work. It lists the fields it covers. They run from public procurement and financial services to product and transport safety, the environment, food safety, public health, and consumer protection. It also reaches fraud against the EU budget and breaches of competition rules. The breach must fall in one of those areas for the shield to apply.

Protection covers a wide cast. It reaches employees and public servants, the self-employed, consultants, shareholders, and board members. It covers volunteers and trainees, paid or not, and people working under contractors, subcontractors, or suppliers. A job applicant who learned of a breach while being hired is covered, and so is a worker whose job has already ended. Facilitators and relatives are protected too, since they can face revenge for someone else's report.

The law calls the protected person an αναφέρων, a reporter. To earn the shield, the reporter only needs a fair belief that the information was true when they spoke up. A wrong report made in good faith still counts. A few matters sit outside the law, such as classified information, legal and medical privilege, and the rules of criminal procedure.

Greece also lets people report without giving a name. The law does not force an organisation to act on an anonymous report. But it does not bar one either. And if an anonymous reporter is later identified and then punished, the same protection kicks in. Their name only loses its cover when a court or an investigation demands it.

"Persons who report breaches are entitled to protection provided that, at the time of the report, they had reasonable grounds to believe that the information on the reported breaches was true and fell within the scope of this law."
Article 7 of Law 4990/2022

Who must appoint a Report Receipt and Monitoring Officer?

The duty falls on every public body and on private firms with 50 or more workers. The person who runs the in-house channel has a formal title in Greece. They are the Report Receipt and Monitoring Officer (Υπεύθυνος Παραλαβής και Παρακολούθησης Αναφορών, or Υ.Π.Π.Α.). The officer receives each report, keeps the reporter's name secret, and tracks the case to its end.

Headcount is not the only trigger. A firm in financial services, transport, or the environment must appoint an officer whatever its size. Smaller public bodies lean on an existing role. In a public body with up to 49 staff, the Integrity Adviser (Σύμβουλος Ακεραιότητας) acts as the officer. Private firms with 50 to 249 workers may share one officer between them to keep the cost down.

The first employers had to move on a clear timetable. Large private firms, those with more than 249 staff, had six months from the law taking effect. Mid-sized firms, those with 50 to 249 staff, had until 17 December 2023. A firm that fails to appoint an officer faces an administrative fine from the Labour Inspectorate, which also reports the gap to the Transparency Authority.

How do you set up the internal channel?

The channel must take a report in writing, by phone or voice message, or through an electronic platform, and it must stay open to a face-to-face meeting on request. The officer has to confirm receipt within seven working days. They then give the reporter feedback within a reasonable time, and never more than three months. The same officer can be an employee or an outside party the firm brings in.

"The Report Receipt and Monitoring Officer acknowledges receipt of the report to the reporter within seven working days of the date of receipt ... and provides feedback within a reasonable period that does not exceed three months."
Article 10 of Law 4990/2022

The officer's job runs past the inbox. They must show staff how to file a report and post that notice where people can see it. They keep in touch with the reporter and can ask for more facts. When a claim belongs to another body, the officer passes it on. They also help shape the firm's training on ethics and integrity.

A spoken report leaves a record the reporter controls. The officer can take it by phone or in a meeting. If the call is taped, or written up as minutes, the reporter gets to check it, fix it, and sign it. Nothing goes on file behind their back.

WeMoral locks every report to the Report Receipt and Monitoring Officer alone. Greece treats a leaked identity as a crime that can carry prison, so that seal is not a nicety. Its reporting platform accepts written and spoken reports and stays usable for people with disabilities, the way Article 10 spells out. WeMoral answers what Law 4990/2022 asks of the internal channel and ships as confidential, EU-hosted whistleblowing software. The law lets that officer be an outside party, and WeMoral can take the seat. You can put the internal channel in place in a day.

What happens when you report to the National Transparency Authority?

The outside route runs through one body. Greece named the National Transparency Authority (Εθνική Αρχή Διαφάνειας) as the authority for external reports. A whistleblower can go there after the internal channel, or head straight to it. The Authority confirms receipt within seven working days and gives feedback within three months, or six in cases it can justify. You can read the channel rules on the Authority's own site.

"The National Transparency Authority is designated as the authority competent to receive, manage and monitor the reports submitted to it directly that concern breaches falling within the scope of this law."
Article 11 of Law 4990/2022

One area has its own door. For breaches of the EU competition rules, Articles 101 and 102 of the Treaty, the external channel is the Hellenic Competition Commission, not the Transparency Authority. Going public is the last resort, and the law fences it in. A whistleblower keeps protection for a public disclosure only in a few cases. One is when the official channels failed to act in time. Another is a clear and present danger to the public interest.

What protection do whistleblowers get?

The law bans revenge outright. It spells out sixteen forms of payback, from dismissal and demotion to a pay cut, a forced transfer, a bad reference, a pulled licence, and even an order to take a psychiatric exam. A reporter also carries no liability for obtaining the information or for the disclosure itself, as long as they had fair grounds to believe it was needed to expose a breach.

The case is tilted toward the reporter. If a whistleblower suffers harm after speaking up, the law presumes the harm was revenge, and the employer must prove otherwise. A dismissal that amounts to retaliation is void. The reporter can claim full damages for the harm they suffered.

"Where a person who has made a report or public disclosure suffers harm, it is presumed that the harm was inflicted in retaliation for the report or the public disclosure."
Article 20 of Law 4990/2022

Greece backs the shield with real support. A reporter has a right to free legal advice and free legal aid, regardless of the means test that usually applies. The Ministry of Justice keeps a list of lawyers for the job. The reporter also has a right to free psychological support, a help the statute names in its own right, with the Ministry of Health keeping a list of psychiatrists and psychologists.

What does breaking Law 4990/2022 cost?

Greece chose a hard line on penalties. Unlike many countries that lean on fines alone, it backs the law with criminal sanctions. Blocking a report, taking revenge, or unmasking a reporter can bring imprisonment and a fine. A knowingly false report carries a term of at least two years. The figures below come from the text of the law.

Two things set Greece apart. One is the threat of prison, which puts a sharper edge on the duty than a fine a large firm could absorb. The other is who pays for the fallout. A Greek whistleblower can claim a lawyer and a psychologist at the state's cost, win or lose. Greece is making a plain bet. People speak up when the price of silence is high and the cost of coming forward is not theirs to bear. To see how Greece lines up with the rest of the bloc, our list of whistleblowing laws by country sets them side by side.