The UK will not be implementing the EU’s Directive on the protection of persons who report breaches of European Union law (the “Whistleblowing Directive”), as the UK has left the EU.

However, organizations in the UK must comply with the Public Interest Disclosure Act 1998 which amended the Employment Rights Act 1996. While these UK laws and the Whistleblowing Directive share some similar features, the protections given to whistleblowers and the compliance obligations placed on organizations differ in some respects.

As such, organizations should ensure that their pan-European whistleblowing compliance measures comply both with both UK legislation and with the laws in EU Member States that implement the Whistleblowing Directive.

Like the EU, the UK has also proposed amendments to its whistleblowing laws, which would establish an independent Office of the Whistleblower in the UK.

We will be closely monitoring the progress of this proposal and any other developments related to UK whistleblowing laws.