Yes, a whistleblower must also be able to report verbally. Offering only a written form is not sufficient: the regulations require a channel that enables both written and verbal reporting. Verbal reporting means: by telephone, via a recorded message, or in a personal conversation if the whistleblower requests it.
As an employer, this means that your chosen reporting channel must support both forms, and that a verbal report is treated in the same way as a written one: with an acknowledgment of receipt, a case code, and the timelines that also apply to written reports.
What the regulations say about verbal reporting
The underlying idea is that a reporting channel must not create barriers. Not every whistleblower feels comfortable putting something in writing, or has the skill or peace of mind to do so. By enabling telephone reporting or recorded messages, the threshold remains as low as reasonably possible.
This does not mean that every employer must staff a telephone line. The point is that the option exists and that a whistleblower who wishes to do so can actually report verbally. How you organize this is up to you, as long as the option genuinely exists and is known to whistleblowers.
What this looks like in practice
With a recorded report, the whistleblower has an opportunity to record their account, often via a secure system, without anyone listening in. The handler then receives a written version or a recording, depending on the setup you chose.
With a conversation on request, for example with the handler or a confidential advisor, the same principle applies: the conversation is documented, and the whistleblower has the opportunity to review that documentation before it is considered a report. This way the whistleblower knows nothing was written down incorrectly, and you as an employer have a reliable file.
One important point is that a request for a conversation is accommodated within a reasonable timeframe. Waiting lists of weeks are not consistent with the idea of an accessible channel.
Documenting without burdening the whistleblower
Documentation is necessary, but must not place an additional burden on the whistleblower. This means, among other things, that a recorded message is not simply transcribed by someone unrelated to the matter, and that a conversation is not recorded without the whistleblower's knowledge. The whistleblower must know what happens to their words.
For the handler, it is practical to have verbal and written reports come together in the same treatment environment, so that the timelines for acknowledgment of receipt and feedback do not need to be tracked separately per reporting form. how that documentation and the timelines work together shows what that looks like in practice.
Verbal reporting and anonymity
Verbal reporting and anonymous reporting are two separate matters that are often confused. A whistleblower can report verbally and still give their name, and a whistleblower can report in writing and remain completely anonymous. With a recorded message via a properly set up system, a voice does not need to be traceable to a name, as long as no additional identifying information is requested.
Employers setting this up for the first time sometimes underestimate how much goes into combining verbal reporting with a genuine anonymity guarantee. A good preliminary check helps: see in a few questions what needs to be arranged for your organization gives you an initial picture of this.
What this means for your reporting procedure
In the reporting procedure that you present to employees, it should concretely state how an oral report works: via which number or which system, and what the employee can expect. Vague formulations such as "get in touch" do not meet the idea of an accessible, recognizable channel.
The knowledge bank with explanations by topic goes into more detail on what exactly such a procedure should contain, and the overview with frequently asked questions addresses similar practical questions that arise when setting up a reporting channel.
Are you unsure whether your current channel already facilitates oral reporting well enough? Do the free quick-scan or browse through the knowledge base; both give you without obligation a first, concrete picture of where you stand.