New Whistleblowing Guidelines Adopted

Source: https://www.anticorruzione.it/-/del.n.478-26.11.2025.llgg.wb

Long title:
Italy’s National Anti-Corruption Authority has adopted new Guidelines on internal whistleblowing reporting channels, following public consultation.

Update Summary:
On 26 November 2025, Italy’s National Anti-Corruption Authority (ANAC) issued new Guidelines no. 1/2025 on whistleblowing on internal reporting channels by Resolution no. 478/2025. The Guidelines clarify how public and private entities must design, operate, and manage internal reporting channels under the whistleblowing law – Legislative Decree no. 24/2023 – which was adopted to transpose the EU Whistleblowing Directive. ANAC also published a companion document explaining which recommendations from the public consultation were accepted or rejected.

Key Highlights / Findings:

Adoption following consultation – The Guidelines were approved after a public consultation held from 7 November to 9 December 2024, with ANAC publishing a dedicated document explaining its responses to stakeholder submissions.
Scope and purpose – The Guidelines provide detailed operational and interpretative guidance on internal reporting channels, complementing (but not replacing) ANAC’s 2023 Guidelines on external reporting procedures.
Internal channel governance – The text clarifies requirements concerning the designation, independence, and conflict-of-interest safeguards of internal channel managers, including rules on cumulation of roles and outsourcing.
Reporting modalities – Entities must ensure both written and oral reporting options, with a strong preference for secure digital platforms that guarantee confidentiality and data protection.
Sanctions and compliance – Failure to properly involve trade unions, ensure confidentiality, or operate compliant internal channels may expose organisations to administrative sanctions under Legislative Decree no. 24/2023.
Updated external reporting framework – In parallel, ANAC amended its Guidelines on external reporting channels, which are mandatory under Italian law; civil society organisations plan to analyse these changes in early January 2026.

Expert Commentary:
A detailed civil society assessment of the internal and external reporting Guidelines is expected in January 2026.

Background & Context:
Italy transposed Directive (EU) 2019/1937 through Legislative Decree no. 24 of 10 March 2023, establishing mandatory internal and external whistleblowing channels and assigning ANAC a central role in oversight and guidance. The 2025 Guidelines respond to implementation challenges identified by ANAC’s 2023–2024 monitoring and aim to promote uniform application of whistleblower protections across the public and private sectors.

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