Is there any change this year in who may handle reports?
At EU level, there is no change to the core rule: the handler of reports must be independent and able to act impartially. This requirement is set out in the underlying directive and is not subject to annual revision. What can change is the way member states implement this requirement nationally: who within an organization may fulfil that role, what knowledge or experience is required, and how impartiality must be demonstrably documented.
For an SME, this means above all that the core question does not change, but the details of the national implementation can shift. This is particularly relevant if your organization operates in multiple EU countries, or if the person who is currently the handler takes on a different role within the company.
What is established at EU level
The directive that underpins the reporting obligation states that the handling of reports must be carried out by a designated, impartial person or department. This person must not be in a position where they have an interest in the outcome of a report, and must be able to assess the report independently without intervention from, for example, a manager who could themselves be the subject of a report. This principle is not subject to annual revision and forms the basis on which national legislation builds.
What can differ by country
The precise implementation of impartiality, and sometimes also training requirements or registration obligations for the handler, is laid down in the national law of each member state. These national laws are sometimes supplemented or clarified, for example in response to practical questions or decisions by a supervisory authority. What has been established in one country for some time may still be developing in another. For an organization that operates only in the Netherlands, this is usually a matter of continuing to follow the national text. For an organization with operations in multiple countries, it is advisable to check for each country whether the requirements for the handler have remained the same or have been tightened.
Why this matters especially when the organization grows or changes
The question of who may be the handler usually only becomes concrete when something changes: a new HR manager, a reorganization, or expansion into another EU country. It is precisely at such moments that it is useful to check whether the designated person still meets the current national implementation of impartiality, not only what was in place when the reporting scheme was first established. Who may designate handlers and where impartiality is tested in practice is described in the knowledge base on the impartial handler.
How to keep track of this for your organization
Because the national implementation can shift without the EU rule itself changing, it is important for employers not to rely on a one-time check. A brief annual review of the handler's role, linked to the countries in which your organization operates, prevents a change from going unnoticed. With a few questions you can see where your organization stands on this obligation, and in the explanation of where our information comes from you can read how we monitor changes in national legislation.
These topics often raise similar follow-up questions, for example about who exactly may be designated or what happens if that person changes role. Some of these are answered in frequently asked questions about the handler.
Do you not yet have a clear picture of your situation, or would you just like to check whether anything has changed this year that is relevant to you? Take the free quick scan or browse through the knowledge base; both can be consulted without an account and provide a concrete answer immediately.