In December 2021, the European Whistleblower Protection Directive reached its implementation deadline for the EU Member States, where Sweden is included. Since then, the Directive has been either implemented or discussed across virtually all the Member States.

The European Whistleblower Protection Directive aims to lay a minimum framework to promote a safe and secure way for employees to good-faith report on potential breaches of laws and misconduct in their work environment. 

The Directive application extends to organizations with more than 50 employees, with an implementation window period of up to the 17th of December 2023 for organizations with less than 249 employees. 

As the number of Member States finalizing their implementation of the Directive keeps growing, more and more companies, municipalities and public authorities across the EU are required to comply.

The obligation to establish a whistleblower reporting mechanism also applies to organizations in the financial sector, irrespective of their size, due to the risks associated with money laundering and terrorism financing.

KPMG Whistleblower Channel

To support our clients in meeting the requirements of the Directive, KPMG Sweden has developed the KPMG Whistleblower Channel, a complete solution and managed service that includes implementation of the reporting channel, triage and handling of cases, with an initial assessment of incoming cases and the provision of relevant advice on next steps. 

How can we help you

KPMG can help your organization by providing:

  • An end-to-end whistleblowing solution;
  • An intake unit equipped with the necessary local expertise and knowledge;
  • Qualified and reliable investigators who can pick up the details from the time a report is submitted and streamline the case through investigation until resolution;
  • A global team of experts who can support you at any stage of the whistleblowing process.

The transposition status of the EU Whistleblower Directive

The EU Whistleblower Directive was transposed into Swedish law on 1st of December 2021.

Outside of Sweden, the Directive remains at different stages of implementation across EU countries, with slightly more than a third of them having fully implemented it as of December 2022.


Do not hesitate to contact us with your questions.

Transposition status

As EU legislators have opted for a minimum harmonization, EU Member States are given a wide degree of autonomy in implementing the Directive. This results in notable differences on some key aspects of the Directive, such as: 

  • The acts, types of misconduct or potential violations of specific laws which can be reported via whistleblowing;
  • The right to anonymity for whistleblowers;
  • The ways and manners in which whistleblowers are allowed to report their grievances (e.g., in written form, via online platforms, via phone, via physical meetings etc.). 

Despite the national differences, the Directive has thus far managed to achieve the goal of establishing a minimum legal framework for whistleblowers in the countries where it has been implemented. This minimum framework includes the prohibition of retaliation against whistleblowers and the obligation for legal entities within the scope of the Directive to set up reporting channels for employees to be able to disclose violations of EU law (although Member States are free to expand the range of the violations which may be reported).