Independent Whistleblower Protection Authority publishes a recommendation for the design and implementation of an internal information system
26 January 2026
On 14 January 2026, the Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante) published Recommendation 1/2026 on the design and implementation of an internal information system. This recommendation addresses several interpretative issues around the internal information system that entities subject to Law 2/2023 on whistleblower protection must implement. Although not binding, it also establishes criteria to help these entities adapt their systems to comply with Law 2/2023. These criteria will also likely serve as a benchmark for the AIPI’s evaluation of such systems when exercising its other functions (such as its sanctioning powers). It is therefore advisable for entities subject to Law 2/2023 to review how their internal information systems are designed to ensure compliance with the new recommendation.
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