Shared reporting office

A shared reporting office is an internal reporting channel that several legally independent companies establish and operate together. The German Whistleblower Protection Act (HinSchG) requires every employer with, as a rule, at least 50 employees to operate an internal reporting office. To reduce effort and cost, the Act expressly allows the necessary resources to be pooled and a reporting office to be used jointly, instead of each company having to maintain a fully separate structure of its own.

The permissibility of such pooling is, however, tied to strict conditions. Under Section 14 (2) HinSchG, private employers with, as a rule, 50 to 249 employees may set up and operate a shared office for running their internal reporting channels. For larger companies with 250 or more employees, a genuine shared reporting office with pooled resources is in principle not permitted according to the official legislative reasoning; they may only share individual tasks such as technical infrastructure or the external engagement of third parties, but must retain responsibility for the reporting office themselves.

What matters is that pooling does not erode the statutory protection standards: confidentiality of the whistleblower's identity, independence of the persons entrusted with case handling, avoidance of conflicts of interest, and compliance with the deadlines (acknowledgement of receipt within seven days, feedback within three months) must be preserved for every participating company. Legal responsibility for the obligations under the HinSchG remains with each individual employer; a shared reporting office relieves the organisational burden, but not the liability.