What is a whistleblower scheme?
An internal system that allows employees and business partners to confidentially report serious legal violations and other serious matters.
gavel Organisational compliance
Not a physical inspection. It concerns policies, procedures, IT systems, and documentation.
Based on Act No. 1436/2021, EU Directive 2019/1937, and the Danish Ministry of Justice Guidance VEJ 9250/2021.
Who must have a whistleblower scheme?
All private and public workplaces with 50+ employees (average over 4 quarters, counted per CVR number).
Danish legislation goes beyond the EU directive — also covers serious violations of Danish law.
Financial companies and AML-covered entities: obligation at 5+ employees, must allow anonymous reporting.
Deadlines
| Category | Deadline |
|---|---|
| 250+ employees (private) + public 50+ | 17 December 2021 |
| 50–249 employees (private) | 17 December 2023 |
| Financial companies (5+ employees) | 17 December 2021 |
| AML-covered entities (5+ employees) | Already in effect |
| Under 50 employees (general) | No obligation (voluntary) |
Consequences of missing scheme
warning Risks of missing whistleblower scheme
- Fine: For failure to establish a whistleblower scheme (§30).
- Procedural fine: For non-compliance with procedural requirements (7-day acknowledgement, 3-month feedback).
- Confidentiality: Fine for breach of confidentiality regarding the report's content or the whistleblower's identity.
- Compensation: Compensation to whistleblower for retaliation (first ruling: DKK 100,000, October 2024).
- Reversed burden of proof: Employer must prove that any disadvantage is not caused by the report.
Requirements for the scheme
Reporting channel
Written and/or oral. IT platform recommended. Anonymous reporting not mandatory but recommended.
Whistleblower unit
Min. 1 impartial person, independent of daily management. Recommendation: 2 persons. Duty of confidentiality.
Procedural requirements
7-day acknowledgement, 3-month feedback, registration of all reports.
Sample Checklist — Establishing the Scheme
Excerpt from Normo's bilingual checklist for establishing a whistleblower scheme. The complete checklist with all checkpoints is available in the PDF guide.
| Checkpoint (DK) | Checkpoint (EN) | Type |
|---|---|---|
| Er virksomheden omfattet af whistleblowerloven? (50+ ansatte) | Is the company covered by the Whistleblower Act? (50+ employees) | Fixed |
| Er intern indberetningskanal etableret? | Is an internal reporting channel established? | Fixed |
| Kan der indberettes skriftligt? | Can reports be submitted in writing? | Fixed |
| Kan der indberettes mundtligt? | Can reports be submitted orally? | Fixed |
| Er anonym indberetning mulig? | Is anonymous reporting possible? | Fixed |
| Er whistleblowerenhed udpeget? | Is a whistleblower unit designated? | Fixed |
| Er personerne uafhængige af daglig ledelse? | Are persons independent of daily management? | Fixed |
| Databehandleraftale indgået med platformudbyder? | Data processor agreement signed with platform provider? | Custom |
Download Complete Guide
10 pages with legal requirements, scheme requirements, 7 complete checklists, and GDPR compliance.
download Download PDFUse the checklists digitally in Normo
Stop the manual paperwork. With Normo, you get all whistleblower checklists digitally.
- check Annual compliance review automatically scheduled
- check Documentation of policies, procedures, and GDPR
- check PDF reports ready for the Data Protection Agency and management