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can a self-employed contractor working for us also use the reporting channel

Self-employed persons can usually also report

Yes, a self-employed person who performs work for an organization generally falls within the group of persons who can use the reporting channel. The whistleblower protection is not limited to people with an employment contract; it is intended for anyone who, through their work, has sight of possible breaches within an organization, and this applies equally to a self-employed person carrying out assignments as to someone on the payroll.

In practice, this means that a reporting channel must not be restricted to only "own personnel". If a self-employed person, freelancer or independent contractor works for an organization for a longer or shorter period and thereby detects something that according to the definition of a breach is relevant, they fall within the group that can rightfully contact the reporting channel of that organization. This aligns with a broader principle: people who no longer work or do not yet work for an organization can also fall under the protection in certain circumstances, as can also be read in the question of whether a job applicant can make a report.

The broad scope of persons in the Directive

This broad framework follows from Article 5 of Directive (EU) 2019/1937, which contains the definitions of who can be considered a reporting person, and from Article 2 of that same Directive, which describes the material scope of application. Together, these articles point to a scope that is explicitly broader than only employees with an employment contract: self-employed persons who work for an organization also fall within the protection that the Directive aims to achieve. The Dutch Whistleblower Protection Act elaborates this principle in Dutch legislation. For the question of whether an organization is required to establish a reporting channel at all, the threshold of fifty employees set out in Article 8 of the Directive remains decisive; that threshold concerns the obligation of the organization, not the question of who may use it. See also for that threshold the explanation about from what number of employees a reporting channel is required. For the precise implementation and any limitations, the official text of the Directive and the Act are decisive; the House for Whistleblowers also provides practical information for employers.

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This is not legal advice. This page provides general information on the legislation this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections are prioritized.