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ARTICLE · 02 FEBRUARY 2026

Whistleblowing: Ensure Programs Are Fit For 2026

A&O Shearman
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Whistleblowing regimes continue to develop across major markets, with new offenses, expanded protections, and regulator expectations converging on faster triage, anti‑retaliation, and high‑quality investigations and documentation.

United StatesEmployment and HR
David Schmid
David Schmid
Hippolyte Marquetty
Hippolyte Marquetty
Amy Edwards
Amy Edwards
Adam Kowalczyk
Adam Kowalczyk
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Whistleblowing regimes continue to develop across major markets, with new offenses, expanded protections, and regulator expectations converging on faster triage, anti‑retaliation, and high‑quality investigations and documentation.

Enforcement bodies are increasingly coordinating internationally and signalling closer scrutiny of programme effectiveness, privilege handling, and data governance, especially where reports implicate sanctions, ESG, cyber, and AI‑enabled misconduct. We see increased efforts by regulators to convince whistleblowers to report things to them, outside of organizations, so the importance of fostering an internal speak-up culture has never been greater. This article outlines key whistleblowing challenges for multinationals in 2026.

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