Whistleblower law in Poland #
Poland implemented Directive (EU) 2019/1937 through the Act of 14 June 2024 on the Protection of Whistleblowers. The Polish regime uses a broader 50-person threshold based on gainful work, not just standard employees.
Applicable law #
- Act of 14 June 2024 on the Protection of Whistleblowers — official text PDF
- Ombudsman information for external reports
Who must establish an internal channel #
Internal reporting procedures are mandatory for legal entities for which gainful work is performed by at least 50 persons. This threshold is broader than a simple employee headcount. Internal obligations started on 25 September 2024.
External reporting authority #
The Rzecznik Praw Obywatelskich (Ombudsman) receives external reports and routes them to the competent public authority where required. External reporting started on 25 December 2024.
Data protection authority #
For GDPR complaints about how whistleblowing data is processed, the relevant authority is the Urząd Ochrony Danych Osobowych (UODO) .
Key compliance points #
- Poland’s threshold counts persons performing gainful work, not only standard employees.
- Local governments may organise joint internal procedures through shared-service arrangements.
- The rollout is split: internal reporting from 25 September 2024, external reporting from 25 December 2024.
Official sources #
- Act of 14 June 2024 on the Protection of Whistleblowers — official text PDF
- Ombudsman — whistleblowers page
- Ombudsman — act enters into force notice
- UODO — whistleblowing and data protection
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