Compliance

Whistleblowing 2026 — Obligations for Companies Employing 50+ People

May 2, 2026 ~7 min read

In September 2024, the Polish Whistleblower Protection Act came into force, implementing EU Directive 2019/1937. As of 2026, obligations apply to all companies employing more than 50 people (with exceptions for financial and sensitive sectors — from 0 employees). Non-compliance carries fines up to 100,000 PLN and criminal liability for management.

Article illustration — Księgowość 365

Who Is Covered by the Act

  • Companies employing 50+ people — full obligation (reporting channels, internal policy, whistleblower protection)
  • Financial sector (banks, insurers, funds) — from 1 employee
  • Anti-money laundering / anti-corruption sector — from 1 employee
  • Public sector — all offices, institutions, and local government bodies

The employment threshold is calculated as an annual average — it includes employment contracts, civil-law contracts (zlecenie), and B2B arrangements with a dominant contract.

What Your Company Must Have

  1. Internal reporting channel — telephone, email, online form, or in-person meeting. Anonymous and available 24/7
  2. Reporting policy — a written document describing the procedure, deadlines, and protections
  3. Designated person — typically HR, a compliance officer, or an external provider
  4. Report register — a record of all reports (anonymized but chronological)
  5. Employee consultation — before introducing the policy and during any changes

What Can Be Reported

A whistleblower reports breaches of law in the following areas:

  • Public procurement
  • Financial services, taxation, AML
  • Environmental protection
  • Food and feed safety
  • Public health, consumer protection
  • Privacy and personal data protection
  • Network and information systems security

Matters outside the scope of protection — interpersonal complaints (mobbing, discrimination) follow separate procedures.

Whistleblower Protection

A whistleblower is protected against:

  • Dismissal from employment
  • Unfavourable changes to working conditions
  • Denial of promotion, bonuses, or training
  • Mobbing and workplace isolation

Retaliatory actions = disciplinary and criminal liability for the employer. The whistleblower is entitled to compensation (no less than 12 monthly salaries).

Frequently Asked Questions

Does the report have to be in writing?
No. A whistleblower can report orally (phone, meeting), in writing (email, letter, form), or anonymously. Every form of report must be accepted.
What if my company has 49 employees?
There is no obligation to establish internal channels, but an employed whistleblower can report directly to PIP (National Labour Inspectorate), the prosecutor's office, or other authorities. Small companies are also prohibited from retaliating.
What are the penalties for non-compliance?
Up to 100,000 PLN fine for the company + personal criminal liability for management (up to 1 year imprisonment for obstructing reports).

Need Assistance?

The Księgowość 365 team — experienced accountants — will handle your bookkeeping and settlements in line with current regulations. First online accounting consultation is free.

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