Danish Whistleblower Act (Act no. 1436/2021)
Danish companies with 50 or more employees must operate an internal whistleblower scheme. See the requirements, the 7-day and 3-month deadlines, and the sanctions.
Who is covered?
All private companies in Denmark with 50 or more employees must establish an internal whistleblower scheme. The Act (no. 1436 of 29 June 2021) implements the EU Whistleblower Directive (2019/1937).
The threshold is counted in headcount, not full-time equivalents — part-time employees count in full. Certain sectors (e.g. financial services) are covered regardless of headcount under special rules.
What do the rules require?
What the Act requires
- A secure reporting channel allowing written and/or oral reports
- Confidentiality of the reporter's identity — access restricted to designated persons
- An impartial person or unit to receive and follow up on reports
- Acknowledgement of receipt within 7 days
- Feedback on the follow-up within 3 months of the acknowledgement
- A written whistleblower policy explaining how to report
- Protection against retaliation — dismissal, demotion or harassment of reporters is prohibited
- GDPR-compliant processing and storage of reports
Deadlines and sanctions
Deadlines and sanctions
- Acknowledgement within 7 days, feedback within 3 months — per report
- Failure to establish a scheme can be punished with a fine
- Retaliation against a reporter can trigger compensation — and the burden of proof shifts to the employer
- Breach of confidentiality about the reporter's identity is also punishable by fine
How to comply with Verkta
Verkta's whistleblower portal gives you a secure, anonymous reporting channel in 25 languages, ready the same day. The system acknowledges receipt and tracks the 7-day and 3-month deadlines with automatic reminders for your case handlers. Access is restricted to designated persons, and every action is recorded in a full audit trail. A whistleblower policy template is included, so your documentation is complete too.
Frequently asked questions
›Do part-time employees count towards the 50?
Yes. The threshold is based on headcount, not full-time equivalents. Temporary agency workers count at the agency that employs them.
›Must the channel accept anonymous reports?
The Act does not force you to offer anonymity, but if you receive an anonymous report you must handle it. In practice an anonymous channel is strongly recommended — it builds trust and increases genuine reports.
›Can group companies share one scheme?
Companies with 50-249 employees may share certain resources for receiving and investigating reports, e.g. within a group. Each legal entity must still fulfil its own obligations towards its own employees.