WeMoral 2026 Report on Whistleblower Directive Transposition Across the EU
How 27 member states transposed Directive 2019/1937, and where their laws still disagree on fines, anonymity, deadlines and protection.
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Two member states were on time.
One was 1,013 days late.
The directive's transposition deadline was 17 December 2021. Every bar below is one member state's delay past that date.
Days between the 17 December 2021 deadline and the entry into force of each national law.
Source:
WeMoral, 2026 Report on Whistleblower Directive Transposition Across the EU, p. 6.
One directive, 27 different laws
The directive promised one standard of protection across the EU. The transpositions kept the outline and rewrote the details.
member states transposed on time, Denmark and Sweden, both on 17 December 2021. Nobody was early.
Poland's delay, the longest in the EU. The average member state was more than a year late.
Spain's maximum fine for a non-compliant entity. Six member states set none at all.
member states created no criminal offence around whistleblowing. Eight threaten prison.
member states force companies to accept anonymous reports. Three others bar or exclude them.
have no compliance supervisor at all, so nobody checks whether internal channels exist.
Four sections, every member state
- Key findings
Eight numbers that measure the gap between the laws
- Scope, who must comply
Transposition delays, company-size thresholds, the public sector, phase-in dates and group-wide channels
- Reporting channels and process
Anonymous reports, written and oral intake, acknowledgement and feedback deadlines, who runs the channel, retention
- Protection and remedies
What can be reported, who is protected, immunity, remedies for retaliation, the burden of proof and NDAs
- Enforcement and sanctions
Who supervises compliance, fines on companies, criminal penalties and the reporter's own risk
- References
Every national statute cited, article by article
How long a company may take to respond
The directive gives an internal channel three months to come back to the reporter. Five member states cut that short.
How long an internal channel has to give the reporter feedback, per member state.
Source:
WeMoral, 2026 Report on Whistleblower Directive Transposition Across the EU, p. 17.
“A worker who reports the same wrongdoing in Madrid, Tallinn and Budapest is protected by three materially different laws, and in one of them has no civil remedy at all.”
WeMoral, 2026 Report on Whistleblower Directive Transposition Across the EU, p. 4
Every value cites the exact article
Each national law was analysed in detail, and every value in the comparison tables points back to the statute behind it.
Get the full country-by-country comparison
All 27 member states, 33 data points each, with the exact article behind every value. Free PDF.
Download the reportThe report is a comparative analysis of published legislation and is not legal advice. Before acting on anything in it, confirm the current position with qualified local counsel.