ANAC — Italy’s external reporting channel #

The Autorità nazionale anticorruzione (ANAC) operates the external reporting channel established by Legislative Decree no. 24 of 10 March 2023. It receives reports, investigates, gives feedback to the reporting person, and imposes the administrative fines the decree provides for.

This page is a reference on the Authority: when a person may turn to it at all, how a report is filed, which deadlines apply, what happens next, and what ANAC can fine. For the internal-channel duty, thresholds and personal scope, see whistleblower law in Italy .

What ANAC is for the purposes of the decree #


Authority	Autorità nazionale anticorruzione (ANAC)
Source	Legislative Decree no. 24 of 10 March 2023, arts. 6–9 and 21
Role	Operator of the external reporting channel (art. 7(1))
Effective from	15 July 2023; for private entities with up to 249 workers the internal-channel duty runs from 17 December 2023 (art. 24(1) and (2))
Sanctioning power	Administrative fines from €500 to €50,000 (art. 21)

When external reporting is available at all #

This is what sets Italy apart from most other member states, and it is also the point most often reported incorrectly.

External reporting is not a free alternative to internal reporting. Article 6(1) allows it only where, at the time it is submitted, one of these conditions applies:

(a) the reporting person’s work context provides no mandatory internal channel, or the channel, though mandatory, is not active, or, though activated, does not comply with art. 4;
(b) the reporting person already made an internal report under art. 4 and it was not followed up;
(c) the reporting person has well-founded reasons to believe that an internal report would not be effectively followed up, or that making one could create a risk of retaliation;
(d) the reporting person has well-founded reason to believe the breach may constitute an imminent or manifest danger to the public interest.

In Spain and Germany the choice between the internal and external route is free. In Italy it is not: someone who goes to ANAC without one of those four conditions is outside the perimeter of art. 6.

The external channel #

ANAC operates a channel that guarantees, including through the use of encryption, the confidentiality of the identity of the reporting person, the person concerned and any person mentioned in the report, as well as of the content of the report and its documentation (art. 7(1)).

The same confidentiality applies where a report arrives through other channels or reaches staff not assigned to handling reports, to whom it must in any case be transmitted without delay.

External reports are made (art. 7(2)):

in writing through the online platform;
orally by telephone line or voice-messaging system;
at an in-person meeting, at the reporting person’s request, arranged within a reasonable time.

The Authority’s platform is at whistleblowing.anticorruzione.it .

An external report submitted to a body other than ANAC must be transmitted to ANAC within seven days of receipt, with simultaneous notice to the reporting person (art. 7(3)).

Anonymous reports #

The decree does not require the channel to accept anonymous submissions. The operative rule is art. 16(4): the protections apply also to anonymous reports, complaints to the judicial or accounting authorities, and public disclosures where the reporting person was subsequently identified and suffered retaliation.

Protection therefore does not depend on having given a name when reporting; it engages once the identity surfaces and retaliation follows.

Deadlines #

The external and internal deadlines are not the same.

	External channel — ANAC	Entity’s internal channel
Acknowledgment of receipt	Seven days from receipt, unless the reporting person requests otherwise or the acknowledgment would prejudice the confidentiality of their identity (art. 8(1)(b))	Seven days from receipt (art. 5(1)(a))
Feedback	Three months, or six months where justified and reasoned grounds exist, from the acknowledgment or, failing that, from the expiry of the seven days (art. 8(1)(f))	Three months from the acknowledgment or, failing that, from the expiry of the seven days (art. 5(1)(d))

The extension to six months is available only on the external channel; the internal deadline cannot be extended. That is the same shape as Germany and the opposite of Spain, where the internal deadline extends and the external one is hard.

What ANAC does after a report #

The Authority designates specifically trained staff and carries out the activities listed in art. 8(1):

Inform any interested person about the use of the external and internal channels and about the Chapter III protection measures.
Acknowledge receipt within seven days.
Maintain contact with the reporting person and request further material if needed.
Diligently follow up the reports received.
Carry out the investigation, including by hearings and obtaining documents.
Give feedback within the deadlines above.
Communicate the final outcome, which may be archiving, transmission to the competent authorities, a recommendation, or an administrative fine.

Limits on what it will do #

Lack of competence. Reports outside ANAC’s competence are sent to the competent administrative or judicial authority, including EU institutions and bodies, with simultaneous notice to the reporting person. The receiving authority performs the activities under letters (c), (d), (e), (f) and (g) and guarantees the same confidentiality (art. 8(2)).
Prioritisation. Where there is a significant influx, ANAC may give priority to reports concerning breaches involving serious harm to the public interest or harm to principles of constitutional or EU-law rank (art. 8(4)).
Minor breaches. ANAC may decline to follow up reports of minor breaches and archive them (art. 8(5)).

ANAC also transmits annually to the European Commission the number of external reports received, the number and types of proceedings opened and their outcome, and, where established, the financial damage caused and the amounts recovered (art. 8(3)).

Fines #

Unlike several of its counterparts, ANAC imposes administrative fines directly (art. 21(1)):

Amount	Conduct established
€10,000–50,000	Retaliation; a report obstructed or an attempt to obstruct it; breach of the confidentiality obligation under art. 12 (lit. a)
€10,000–50,000	Failure to establish reporting channels; failure to adopt procedures for making and managing reports, or adoption of procedures that do not comply with arts. 4 and 5; failure to carry out the verification and analysis of the reports received (lit. b)
€500–2,500	The case under art. 16(3), unless the reporting person has been convicted, including at first instance, of defamation or malicious accusation (lit. c)

Two features deserve attention. First, letter (b) does not only penalise the absence of a channel: non-compliant procedures and failure to verify and analyse the reports received sit in the same band — operating a channel nobody investigates is the same offence as having none. Second, the fines are applied to the person responsible, and private-sector entities under art. 2(1)(q)(3) must provide for sanctions in the disciplinary system adopted under art. 6(2)(e) of Legislative Decree 231/2001 (art. 21(2)).

Protection against retaliation #

The protections operate where the person made an internal report, an external report or a public disclosure on the decree’s terms. Retaliation is prohibited (art. 17), and waivers and settlements, whole or partial, concerning the rights and protections the decree provides are invalid unless made in the forms of art. 2113, fourth paragraph, of the Civil Code (art. 22).

The protections are not guaranteed, and a disciplinary sanction is imposed on the reporting person, in the cases of intent or gross negligence established under art. 16(3).

The Authority’s contact points #


Reporting platform	whistleblowing.anticorruzione.it
Offices	Palazzo Sciarra, Via Minghetti 10, 00187 Rome
Institutional site	anticorruzione.it

Article 9 requires ANAC to publish, in a dedicated, easily identifiable and accessible section, the protection measures, its own contact details (stating whether telephone conversations are recorded), instructions on using the channels, the confidentiality regime, the feedback deadlines and the types of follow-up it can give, and the list of third-sector bodies it has agreements with.

Official sources #

Last updated: September 20, 2026