Starting as of 17 December 2023, the new (more strict)
requirements of the Dutch Whistleblower Protection Act regarding
internal reporting procedures for whistleblowers now also apply to
midsize employers (those with 50-249 employees).
As a result of these new requirements, employers must have an
internal reporting procedure in place for the reporting of
suspected wrongdoings that sets out, among other things, how the
report is dealt with, what qualifies as a suspected wrongdoing, to
whom a report can be made, how a report can be made, and within
what time frame a report must be followed up.
With regard to the method of reporting and to whom a report can
be made, a new 'Decree on the anonymous reporting of suspected
abuses' was recently submitted for online consultation. In the
legislative process leading up to the Dutch Whistleblower
Protection Act, it was announced that the option to make an
anonymous report would be included in the law. The Decree is a
further
