Slovenian whistleblower protection law "Zakon o zaščiti prijaviteljev"

Slovenia brought the EU Whistleblower Directive into national law with the Zakon o zaščiti prijaviteljev, or ZZPri, in force since 22 February 2023. The law calls a whistleblower a prijavitelj. It puts the Commission for the Prevention of Corruption at the centre. And it lets a dismissed reporter draw unemployment benefit while the case runs.

What is the ZZPri and when did it take effect?

The ZZPri is Slovenia's transposition of the EU Whistleblower Directive. It was published in the Uradni list, the official gazette, as issue 16/23 and took effect on 22 February 2023. President Nataša Pirc Musar proclaimed it on 4 February 2023, after parliament passed it in late January. The law sets out how to report a breach, how the report is handled, and how the reporter is shielded.

"This Act lays down the methods and procedures for reporting breaches of regulations that individuals learn of in their work environment, the handling of such reports, and the protection of the persons who report or publicly disclose information on a breach."
Article 1, ZZPri

Employers did not all have to be ready on day one. Big private firms with 250 or more staff, and the whole public sector, got 90 days from the law taking effect. Smaller private firms, those with up to 249 workers, had until 17 December 2023. By that second date the duty reached every mid-sized employer in the country.

Who counts as a prijavitelj?

Anyone who learns of a breach through their work. The job title does not matter. What counts is the work setting that put the information in front of you. The law draws the circle wide and names the people it protects, well beyond staff on a standard contract.

The shield reaches:

• workers, current and former, in any employment relationship;
• the self-employed, contractors, subcontractors, and suppliers;
• shareholders and members of management or supervisory boards;
• volunteers, trainees, and apprentices, paid or not;
• job applicants who learn of a breach during hiring.

The cover spreads outward too. A posrednik, the facilitator who helps a reporter come forward, is protected, and so are colleagues and relatives who could face payback for the link. The law also stands behind a reporter who filed with no name attached.

"A reporter who filed a report anonymously, and whose identity was later disclosed, is also entitled to protection under this Act."
Article 5, ZZPri

There is one firm limit on timing. A report filed two years or more after the breach ended falls outside the law. The reporter also has to have had reasonable grounds to think the information was true when they spoke up. Honest mistakes are covered; a deliberate lie is not.

Who is the zaupnik, and what must they do?

The zaupnik is the trusted person who receives and handles internal reports. The employer names one from among its staff, and the role carries real duties. The zaupnik checks each report, decides whether it meets the conditions for handling, and works the case through to a written outcome, free of instructions in any single matter.

Two deadlines bind the work. The zaupnik must confirm a report within 7 days of getting it. They must close the case with a report within 3 months, setting out whether the claim held up and what was done about it. If the reporter gave a name, they learn the result; an anonymous reporter who left a contact point gets the same.

The role does not stop at the inbox. The zaupnik advises a reporter who meets payback, points them to outside bodies and support groups, and issues proof of the filing for any later court fight. Once a year, by 1 March, the employer reports the count of received, anonymous, and well-founded reports to the Commission for the Prevention of Corruption.

How do you set up the internal reporting path?

If you run a public body, you need a notranja pot za prijavo whatever your size. Private firms cross the line at 50 employees. A smaller firm of 10 or more staff still needs one if its main business sits in health, water, waste, or environmental services. Private firms with fewer than 250 workers may share the resources for receiving and investigating reports.

The channel comes with set duties. You fix an email address, a phone line, or another contact point for reports. You guard the reporter's identity and block anyone not cleared to see the file. You write an internal act that describes the path, and you can hand the receiving work to an outside provider rather than keep it in house.

WeMoral is the sealed channel your zaupnik signs into, and it fulfils what the ZZPri asks of the internal path. Each report lands encrypted and stays locked to the handler you name, so no one else in the firm can open it. The law lets that handler be an outside provider, and WeMoral can take the seat just as well as your own appointee. It keeps a time-stamped count of received, anonymous, and well-founded reports, the very figures you file with the Commission for the Prevention of Corruption by 1 March. It ships as audit-logged whistleblowing software with nothing to install, so you can open the internal reporting path in a day.

Where do external reports go?

A reporter does not have to go through their employer first. They can file straight with an outside body if no internal path exists, if an internal report would get nowhere, or if they fear payback for raising it inside. The law names 24 external reporting bodies, each one a regulator for its own field.

The list runs across the regulated economy and includes:

• Banka Slovenije, the central bank;
• the agencies for securities markets, competition, and insurance;
• the Financial Administration and the Market Inspectorate;
• the Information Commissioner and the Labour Inspectorate;
• the Commission for the Prevention of Corruption.

The Commission for the Prevention of Corruption plays a special part. When a breach falls in no other body's field, the reporter takes it there. When a report reaches a body that cannot handle it, that body passes it on and still confirms receipt within 7 days, guarding the reporter's name as it goes. The Commission is the backstop that keeps a report from falling through a gap.

How does Slovenia protect reporters from retaliation?

With a broad ban and a reversed burden of proof. The law forbids any payback tied to a report, from dismissal and demotion to pay cuts, bad reviews, blacklisting, and harm to a reputation. A threat to retaliate, or an attempt at it, counts as payback in its own right.

"It is presumed that the harm suffered by the reporter is a consequence of retaliation for the report. The person who took the measure must prove that it was lawful and justified and was not connected to the report."
Article 22, ZZPri

The court route is built to be quick and cheap for the reporter. A retaliation case is urgent, and the reporter pays no court fees. They get free legal aid whatever their income, a clear break from the usual means test. And once a reporter shows they filed and then suffered harm, the employer has to prove the harm had another cause.

Slovenia then adds a safety net few peers match. A reporter sacked for speaking up can claim unemployment benefit as if let go through no fault of their own, even without the usual minimum insurance period, at the minimum rate, until the court rules. If the employer loses, it repays the employment service. The Commission can also arrange psychological support for a reporter worn down by the fallout.

What are the penalties for breaking the law?

Fines that climb with the size of the firm and the gravity of the act. The Commission for the Prevention of Corruption and the external bodies run the penalty proceedings. The table below shows the main offences and the range for each, in euros.

The top band bites a medium or large company. Carry out a reprisal and the fine runs from 10,000 to 60,000 euros; the responsible manager faces a separate fine on top. The figures sit below Spain's million-euro ceiling or Portugal's quarter of a million, yet they reach the people who run the firm, not just the firm itself.

Slovenia's law leans on care more than on cash. Its fines are middling, but its support is not. One body, the Commission for the Prevention of Corruption, advises the reporter, trains the handlers, and keeps the national count, while free legal aid, an unemployment bridge, and psychological help stand behind anyone who pays a price for speaking up. For an employer the task is plain. Name a zaupnik, seal every report, and treat any sanction near a report as one you may have to justify in court. To see how Slovenia lines up with the rest of Europe, read our guide to whistleblower laws by country.