Poland: Whistleblowers’ Internal Reporting Procedures Required Staring January 1st 2025?

The Act on Protection of Whistleblowers does not explicitly specify the date from which employers will be required to have an internal reporting procedure. The Act itself shall come into force on September 25^th 2024, and according to its provisions, entities employing at least 50 people shall be required to announce the internal reporting procedure. Verification of employment levels should be carried out as of January 1^st or July 1^st of a given year. The Ministry of Family Affairs, Labour and Social Policy has issued an interpretation stating that employers will be required to have an internal reporting procedure starting January 1^st 2025 because only from that date will they be able to verify the level of employment in accordance with the provisions of the Act. However, the above issue is still controversial, as some experts fear that the Ministry’s opinion will not be enough to relieve employers of criminal liability for not having an internal reporting procedure after September 25^th 2024.