NFU Consultation Reply to the Whistleblower Directive Review

Summary

Under Article 27(3) of the Whistleblower Protection Directive, the Commission must assess how national laws implementing the Directive are working. In its reply, the Nordic Financial Unions (NFU) recognises progress but identifies persistent gaps—especially concerning anonymity, protection from retaliation, burden of proof, and fair compensation.

NFU calls for stricter EU-level minimums: full reversal of the burden of proof, truly dissuasive compensation, explicit protection against subtle retaliation, guaranteed anonymity, and harmonised cross-border procedures.

The reply argues that the Whistleblower Directive should remain a protective baseline, not a ceiling—ensuring that individuals who speak up are safeguarded across all sectors and member states.