Internal whistleblowing channel
From 50 employees, or with a 231 model: channel, procedures and protection for reporters. ANAC fines up to €50,000.
Source: D.lgs. 24/2023, attuazione della Direttiva (UE) 2019/1937
Who it applies to
Private entities with at least 50 employees (annual average). The obligation applies regardless of size if the company has adopted a 231 compliance model or operates in sensitive sectors such as finance or environmental protection: looking only at headcount is the most common mistake.
What you must do
- Set up an internal channel that protects the confidentiality of the reporter's identity.
- Adopt a written procedure: who handles reports, response times, traceability.
- Inform staff and make it accessible to collaborators and suppliers too.
- Train those managing the channel and keep evidence of reports and outcomes.
When
Ongoing: the channel must stay active and the procedure current. For private entities up to 249 employees the obligation started on 17 December 2023.
Penalties
ANAC administrative fines from €10,000 to €50,000 where the channel is missing, procedures are non-compliant, or in cases of retaliation or breach of confidentiality. €500 to €2,500 for the reporter in cases of established defamation.
What you need at hand
- Written procedure for handling reports
- Register of reports received and their outcomes
- Evidence of staff communication and training delivered
The same data, reused
How it connects to the VSME dossier
This is business-conduct material: in the Basic module it feeds B11 (convictions and fines for corruption and bribery) and, in the Comprehensive module, C6 on human-rights policies and processes, which covers precisely the existence of a complaint-handling mechanism.
organises this data once and makes it reusable for banks, clients and tenders. It does not issue certifications, ratings or assurance.
Informational sheet, not a substitute for professional advice: your situation may depend on legal form, sector, group membership or the compliance model adopted. References verified on 22/07/2026.