1 November 2025 deadline to submit information on whistleblowing reporting channels

At a glance

• The Independent Authority for Whistleblower Protection will commence operations on 1 September 2025.
• Employers have a period of two months from then to provide the Authority with information on who is designated to operate their internal whistleblowing reporting channel.

• As reported in our previous update,  Spain has established an Independent Authority for Whistleblower Protection to fulfil various functions under Spanish legislation implementing the EU Whistleblower Protection Directive. Although Spain's Whistleblowing Act came into force on 13 March 2023, to date the Authority has not started functioning.   
• Under an order published in the Official Gazette on 12 August 2025, the Authority will commence operations on 1 September 2025.
• An important consequence for employers flowing from this date being set is that it triggers the obligation to designate who within the organisation is responsible for operation of the internal whistleblowing reporting channel and to notify the Authority of this.    The information must be provided within two months of the Authority commencing operations, so by 1 November 2025.
• Any subsequent changes to the designated individual responsible for the internal reporting system must be notified to the Authority within ten working days, along with the reasons for the change.