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D.Lgs. 24/2023: Italy's Whistleblowing Decree — Employer Guide

Everything Italian employers need to implement compliant internal reporting under D.Lgs. 24/2023 and GDPR.

Autore: Alexandru Cojoaca

D.Lgs. 24/2023 — legal background

Legislative Decree 10 March 2023, n. 24 implemented Directive (EU) 2019/1937 in Italy. It applies to public and private sectors, defines reporting channels, protects whistleblowers and assigns enforcement roles to the National Anti-Corruption Authority (ANAC) for much of the public sector.

Who must comply?

  • Private employers with more than 50 employees
  • Public administration entities
  • Entities in sectors covered by the decree regardless of size

Channel design requirements

  • Internal channel before external reporting (with defined exceptions)
  • Confidentiality of identity and documentation
  • Acknowledgement within 7 days
  • Feedback within 3 months
  • Register of reports managed by the responsible person
  • Information to workers on procedures and protections

GDPR and whistleblowing in Italy

The Italian Data Protection Authority (Garante) expects data minimisation, limited access, defined retention and secure processing. Cloud solutions must be assessed for transfer risk — EU hosting is strongly preferred.

QReportly for Italian employers

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