No.

Not all companies in the EU are required to have an internal whistleblower channel.

But many more than you might think are covered by the requirement.

Here's what applies in 2026.

The basic rule in the EU

According to EU Directive (EU) 2019/1937 should private companies with 50 or more employees It has internal channels and routines for reporting.

This is the main rule in all member states.

So it is number of employees per legal entity is crucial – not the group's total size.

Do companies with fewer than 50 employees have to have a channel?

As a general rule: no.

However, the directive allows member states to introduce requirements even for companies with fewer than 50 employees, after a risk assessment – especially if the activity poses a risk to the environment or public health.

This means that some countries have chosen to go beyond the minimum level.

Are there countries with exceptions under 50?

Yes – but that usually applies to specific sectors, not all companies.

Example:

• Italy – companies subject to specific compliance requirements (including under so-called Legislative Decree 231/2001) must have reporting channels regardless of their size.

• Germany – companies in certain financial sectors are covered regardless of employee count.

• Austria – certain regulated activities, especially within finance, are also covered under 50.

However, most member states have stuck to the 50 limit as a general threshold.

How is it in Sweden?

In Sweden, the main rule is:

• 50 or more employees → internal whistleblowing channel required.

• Fewer than 50 employees → no general legal requirement.

There is currently no general requirement in Sweden for small businesses to establish internal channels solely due to risk assessment.

So – must everyone have a whistleblower channel by 2026?

No.

Men:

• All companies with 50+ employees must.

• Companies in certain regulated sectors may need to, even if they are smaller.

• The rules differ slightly between member states.

Our advice

Whether or not your company is subject to a formal requirement, our recommendation is clear:

Have an internal whistleblowing channel.

Det:

• building trust with staff

• signals transparency towards suppliers

• strengthens relations with investors

• reduces the risk of cases going directly to authorities or the media

A whistleblowing function is not just a legal issue.

It's a matter of trust and corporate governance.