Können Unternehmen innerhalb einer Unternehmensgruppe einen Meldekanal gemeinsam nutzen?

Sharing is permitted, but only for entities with up to 250 employees

Yes, companies within a group may use shared resources for receiving and investigating reports, but this applies only to entities with 50 to 249 employees. A group whose individual components fall within that range can therefore choose to establish a single reporting channel that operates for multiple subsidiaries simultaneously, with a single reception point and a single treatment structure that follows the same deadlines and procedures for all connected entities.

This exception does not apply to entities with 250 employees or more: these are required to have their own channel, even if they are part of a group that otherwise meets the conditions for sharing. The number of employees of the parent company or the group as a whole is not the starting point — it is the size of the individual legal entity that matters. A group with a large holding company and several smaller subsidiaries may therefore find itself in a mixed situation: the smaller entities share a channel, the larger ones have their own facility. What also remains in place, regardless of whether a channel is shared: the works council of each connected entity retains its own right of approval for the arrangement that applies to that entity, and the deadlines for receipt confirmation and assessment run per report, not per group.

What Article 8 of the Directive regulates

This option follows from Article 8 of Directive (EU) 2019/1937, which forms the basis for national whistleblower laws, including the Dutch Whistleblower Protection Act and the German Hinweisgeberschutzgesetz. The Directive explicitly distinguishes between entities with 50 to 249 employees, which may share resources for receiving reports and for investigation, and larger entities, for which this exception is not provided. For the precise way in which a country has implemented this distinction, the national implementing law is the appropriate source.