18 October 2018

Coherent approach Dutch Whistleblowers Authority internationally unique

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The Netherlands is the only country with a government agency that combines various whistleblowing facilities, and does so for both the public and the private sector. This is the conclusion of Kim Loyens from Utrecht University and Wim Vandekerckhove from the University of Greenwich on the basis of their international comparative research on whistleblowing institutions.

The Dutch Whistleblowers Authority offers advice and psychosocial assistance to whistleblowers, investigates wrongdoing and reprisals against whistleblowers and provides policy advice, with the intention of contributing to the prevention of abuse. The Dutch Whistleblowers Authority does this both in the public and in the private sector, which makes this government agency unique from an international perspective. Several other countries are now considering to adopt such a coherent approach in the protection of whistleblowers and the investigation of wrongdoing they report.

Fragmentation may result in whistleblowers not finding their way to the right authority

Commissioned by the Dutch Whistleblowers Authority, Kim Loyens and Wim Vandekerckhove studied in eleven countries to which extent whistleblowing institutions combine various tasks and how legislation in this field is implemented in various sectors. Using expert interviews, analysis of policy documents and research reports, they conducted research in Australia, Belgium, France, Ireland, Israel, the Netherlands, Norway, Serbia, the United Kingdom, the USA and South Korea.

A coherent approach in the Netherlands

The combination of various tasks and sectors in one Whistleblowers Authority creates challenges in the Netherlands, as was also apparent in the difficult start-up phase. Compared to other countries, there are also important steps to be taken in the Netherlands in the legal protection of whistleblowers. At the moment, the law does not yet provide for the principle of reversed burden of proof and protection when reporting to the media, which are internationally considered good practices.

Finding the right way is important for whistleblowers

In other countries, the challenges lie in a different area. These are the most important findings of the research:


  • The risks of fragmentation: Countries with a more fragmented institutional landscape (such as Australia and the US) often have to deal with the difficult coordination between organizations. Fragmentation may also result in whistleblowers not finding their way to the right authority.
  • More attention needed for the private sector: Whilst whistleblowers in both the public and the private sector enjoy legal protection in most of the studied countries (with the exception of Belgium), whistleblowing institutions often focus only on the public sector. In many countries (such as Australia, Belgium, France and Israel) this is done by the Ombudsman. Only in the Netherlands and the Republic of Korea there is one agency for whistleblowing in the public and the private sector. The protection for whistleblowers in the private sector and investigation of wrongdoing they report therefore require greater attention in most countries.
  • Investing in psychosocial support: Of the countries included in the study, public money is available for specific psychosocial support of whistleblowers only in the Netherlands, Israel and Norway, but some other countries are considering investing in this as well.
  • The role of NGO’s: It is also noteworthy that in countries where no government agency has been set up to implement whistleblowing legislation (including in Great Britain and Serbia), NGO’s offer advice and psychosocial support to whistleblowers, and also act as a center of expertise in the field of whistleblowing policy.

More information

If you would like to read more about this research, please view the report The Dutch Whistleblowers Authority in an international perspective: a comparative study or go the website of the Dutch Whistleblowers Authority.

For further questions please contact Dr Kim Loyens.