> Italy's whistleblower framework under Legislative Decree 24/2023: the 50-worker rule, the Model 231 carve-in, and the official ANAC sources.

Source: https://ethicsportal.eu/whistleblower-laws/italy/
Updated: 2026-04-24

---

# Whistleblower law in Italy

Italy implemented Directive (EU) 2019/1937 through **Legislative Decree No. 24 of 10 March 2023**. Italy's framework is commercially important because it combines the standard **50-worker** threshold with a separate rule for organisations that have adopted a **Model 231** compliance model.

## Applicable law

- [Legislative Decree No. 24 of 10 March 2023 — official text](https://www.gazzettaufficiale.it/eli/id/2023/03/15/23G00032/sg)
- [ANAC whistleblowing page](https://www.anticorruzione.it/en/-/whistleblowing)

## Who must establish an internal channel

Private entities with **at least 50 workers** must establish an internal reporting channel. Italy also requires channels for entities that have adopted a **Model 231** organisational and management model, even where they are smaller.

## External reporting authority

The official external authority is [ANAC](https://www.anticorruzione.it/en/-/whistleblowing), which provides external reporting procedures and public guidance on the Italian whistleblowing regime.

## Data protection authority

For GDPR complaints relating to the handling of whistleblower data, the relevant authority is the [Garante per la protezione dei dati personali](https://www.garanteprivacy.it/).

## Key compliance points

- Italy's Model 231 overlap means the market expects precise legal positioning rather than a generic "50-plus employees" message.
- The Italian regime is documentation-heavy: companies need a clear internal procedure, a designated handler setup and compliant privacy information.
- ANAC remains the central official reference point even when the report concerns a private entity.

## Official sources

- [Legislative Decree No. 24 of 10 March 2023 — official text](https://www.gazzettaufficiale.it/eli/id/2023/03/15/23G00032/sg)
- [Normattiva — Italian legal text database](https://www.normattiva.it/)
- [ANAC — whistleblowing](https://www.anticorruzione.it/en/-/whistleblowing)
- [Garante privacy](https://www.garanteprivacy.it/)

---

[Deploy your reporting channel →](/pricing/)