Can companies within a group share one reporting channel?

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 this range may therefore choose to establish a single reporting channel that operates for multiple subsidiaries simultaneously, with a single reception point and a single handling structure that applies the same timeframes and the same procedure to 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 of the group as a whole is not the starting point — what matters is the size of the individual legal entity. A group with a large holding company and a number of smaller subsidiaries may therefore find itself in a mixed situation: the smaller entities share a channel, the larger ones have their own facility. What remains in any case, regardless of whether a channel is shared: the works council of each connected entity retains its own right of approval regarding the arrangements applicable to that entity, and the timeframes for receipt confirmation and assessment run per report, not per group.

What Article 8 of the Directive regulates

This possibility follows from Article 8 of Directive (EU) 2019/1937, which forms the basis for national whistleblower laws, including the Dutch Protected Disclosures Act (Wet bescherming klokkenluiders) and the German Whistleblower Protection Act (Hinweisgeberschutzgesetz). The Directive makes an explicit distinction 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 manner in which a country has implemented this distinction, the national implementing legislation is the appropriate source.