Whistleblower law in Denmark #
Denmark implemented Directive (EU) 2019/1937 through Act No. 1436 of 29 June 2021 on the protection of whistleblowers, in force since 17 December 2021. Denmark is one of the clearer markets from an implementation perspective because it combines the standard 50-worker threshold with a well-defined National Whistleblower Scheme.
Applicable law #
Who must establish an internal channel #
Public authorities and private employers with at least 50 workers must establish an internal whistleblower scheme. Entities in the financial-services and anti-money-laundering, transport-safety, and environmental sectors are in scope regardless of headcount.
External reporting authority #
The official external route is the National Whistleblower Scheme , which is established within Datatilsynet but operates as a separate national external channel.
Data protection authority #
The GDPR supervisory authority is Datatilsynet , which also hosts the National Whistleblower Scheme institutionally.
Key compliance points #
- Denmark’s national scheme accepts written, oral and in-person reports and explicitly allows anonymous reporting.
- The national scheme is not limited to GDPR issues; official Danish materials say it also covers serious legal breaches and other serious matters within the law’s scope.
- Internal procedures should make clear when a worker should use the employer’s channel and when the national external route is more appropriate.
Official sources #
- Act No. 1436 of 29 June 2021 — official text
- National Whistleblower Scheme — English overview
- Datatilsynet — National Whistleblower Scheme
- Justitsministeriet — guidance for private workplaces
- Justitsministeriet — guidance for public workplaces