Internal or external reporting channel?
This page is not legal advice.
Directive (EU) 2019/1937 and Act 1171/2022 give reporters two main routes: the organisation’s internal channel and an external channel run by the authorities. This guide explains how they relate. It is general information, not legal advice.
The internal channel
Organisations covered by section 10 run their own channel, or outsource its operation (section 11). Designated impartial persons handle reports (section 14), acknowledge receipt within seven days (section 15) and give feedback on measures within three months (section 16). The organisation can often fix the problem fastest, which is why the system puts the internal route first.
The external channel
Section 18 assigns the centralised external channel to the Office of the Chancellor of Justice. The Office forwards a report to the competent authority, or in certain matters to the competent ministry; it does not investigate the substance itself.
When the external route makes sense
- The organisation has no internal channel.
- You have a justified reason to believe the internal report was not followed up.
- You have a justified reason to fear retaliation or that internal reporting would not work.
The Chancellor of Justice’s pages describe these conditions in detail and are the operational instructions for that channel.
What this means for organisations
Section 15 requires organisations to publish clear information about the external channel too. A channel that acknowledges on time, replies and protects identities is the best reason for staff to use it first.