Unlike Dodd-Frank and other whistleblower-protection mechanisms in the United States, the EU Directive is undergoing serious reforms—with lots of challenges arising from discrepancies in political systems and governmental processes among Eurozone countries. But it is a giant stride towards improving freedom of speech as well as accountability and probity in public and private companies. Therefore, comparison between the Act and similar US legislations is quite robust and a promising academic exercise. This is also golden because the UK operates a parliamentary system of government whereas the US runs a presidential model.
The EU Whistleblowing Directive is a vital legislative cog in attempting to prevent breaches of EU law—such as corruption and fraud. It also aims at providing comprehensive protection for any individual or group of people blowing the whistle on wrongdoers across Europe. EU member states are obligated to transpose the Act using their own version as national law by 17 December 2021. But, remarkably, the national laws must include—as a minimum—all whistleblower protections stipulated in the EU Directive although each country is allowed to include more protections as may be desired. More importantly, EU countries can decide on how anonymous reporting should be handled, or if there are circumstances when whistleblowers should receive financial rewards. These commendable improvements are a step in the right direction, especially in this era of COVID-19 when retaliatory actions against whistleblowers have stressed the urgent need for governments to strengthen whistleblower-related laws.