Whistleblowing and internal reporting systems

In Slovakia, employers with at least 50 employees must have one, as must employers in selected sectors regardless of employee numbers, including financial services, transport safety and the environment. Public authorities are covered from 5 employees (§ 10(1) of Act No. 54/2019 Z. z.). In the Czech Republic, obliged entities include an employer with at least 50 employees as at 1 January, unless it is an obliged entity under Czech anti-money laundering law subject to a special regime (§ 8(1) of Act No. 171/2023 Sb.). This AML exception often causes confusion: a company that believes it is outside the requirement may fall within it through another route. We assess precisely whether and to what extent it applies to you.

Yes. Slovak law expressly allows receipt and acknowledgment of reports to be outsourced by contract, and employers with fewer than 250 employees, other than public authorities, may also outsource the investigation itself (§ 10(2) of Act No. 54/2019 Z. z.). Czech law permits another person to operate the internal reporting system, without affecting the obliged entity's responsibility (§ 8(2) of Act No. 171/2023 Sb.). For groups, Czech obliged entities with no more than 249 employees may share a system or use one established by another obliged entity (§ 8(3)), allowing one reporting line to serve several companies. As lawyers, we add statutory confidentiality and independence from internal company relationships.

In Slovakia, receipt must be acknowledged within 7 days and the investigation outcome generally communicated within 90 days of acknowledgment (§ 10(6) and (8) of Act No. 54/2019 Z. z.). In the Czech Republic, acknowledgment is also due within 7 days, but assessment of the report's merits has a stricter baseline of 30 days from receipt. In factually or legally complex cases, this can be extended by 30 days at a time, no more than twice, and the whistleblower must be informed in writing before the period expires (§ 12(2) and (3) of Act No. 171/2023 Sb.). Businesses operating in both countries therefore cannot simply copy the Slovak process into the Czech Republic: the Czech baseline is three times shorter. We configure the system to track time limits by country.

The two countries must be distinguished. The Slovak system also provides for anonymous reports. Czech Act No. 171/2023 Sb. does not generally require them to be accepted or recorded under the statutory regime; a business may establish a broader voluntary channel. If the identity of an initially anonymous whistleblower becomes known to a person who could expose them to retaliation, protection under § 4(3) applies. We assess the separate AML regime independently. The internal policy will set the rules for receiving and investigating reports.

Care is needed: whistleblowers are protected against retaliation, and penalising someone for reporting can be costly. Obtain a legal assessment before taking employment action. We help distinguish legitimate employment grounds from prohibited retaliation.

Implementation is a one-off charge based on the company's size. The external person service is usually covered by a monthly retainer. We confirm both prices in advance and adhere to what we have agreed.