COMPLIANCE UPDATE | Private-sector deadline of 17 December 2023
On 17 December 2023, the whistleblowing obligations under Legislative Decree no. 24/2023 became applicable to many private employers with 50 to 249 workers.
Covered entities must maintain internal reporting channels, protect confidentiality, provide feedback within statutory timelines and prevent retaliation. Data-protection and record-retention rules apply throughout the investigation.
International groups may use a central hotline, but the Italian entity must confirm that the channel, information and governance satisfy local requirements. Works-council or union issues and the allocation of investigative roles may also need attention.
Employers should test the channel, train the receiving team and create a separation between investigation, employment decisions and conflicts of interest. Any adverse action involving a reporter requires careful independent documentation.