Term opens to notify Internal Reporting System Officers

On 9 February 2026, the Independent Whistleblower Protection Authority (IWPA) made available the electronic form aimed at notifying appointments and discharges of internal reporting system officers – this triggers a term of two months, running from 10 February to 10 April 2026, within which to notify existing appointments. From that initial notification, any new appointment or removal must be notified within 10 working days.

IWPA also published Guide 1/2026 on the notification of Internal Reporting System Officers, which sets out the basis for the appointment and notification of Internal Reporting System Officers (Notification to IWPA: procedure). Attached to the document is an explanatory manual for filling in the form and a document of IWPA operator FAQs.

The IWPA also issued Recommendation 1/2026 of the Independent Whistleblower Protection Authority regarding the design and implementation of Internal Reporting Systems, which aims to clarify and guide public and private entities in the correct interpretation and application of their obligations under Law 2/2023 regarding Internal Reporting Systems (IRS). One key point of the Recommendation is its reference to the treatment of whistleblowing channels within groups of companies, where the obligation to implement IRS remains at the level of individual entities; however, shared management is permitted provided that the system in place complies in full with Law 2/2023.

Access to the form and to all the documents referred to above can be found on the Independent Whistleblower Protection Authority's website.

Enlaces relacionados

• November 2024 - The Spanish Government approves the Statute for the Independent Authority for the Protection of Whistleblowers

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