EU Directive Recap: External vs Internal Reporting Channels

The EU Whistleblowing Directive (2019/1937) introduced a clear structure for how individuals can report wrongdoing, dividing the process into two primary paths: internal and external channels. Internal reporting allows employees and collaborators to raise concerns directly within the organization—typically through a secure, confidential system managed by a designated team or external provider. This route gives companies the opportunity to address issues early, correct misconduct, and reduce the risk of legal or reputational fallout. External channels, on the other hand, refer to reports made directly to public authorities designated by each EU member state. These may include anti-corruption bodies, data protection authorities, or financial regulators, depending on the nature of the issue. Whistleblowers can choose either route from the outset, especially if they fear retaliation or believe internal reporting would be ineffective. While the Directive encourages organizations to promote internal reporting first, it protects individuals equally—regardless of the channel they use—provided the information is genuine and relevant. For companies, this means having a clear, accessible internal process in place is not only a legal requirement but also a practical way to build trust and reduce the likelihood of problems escalating to external oversight bodies.

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