On 25 June 2026, Generation 2004 took part in the first social-dialogue meeting on the Commission’s draft Decision revising its existing Whistleblowing Guidelines. 

The revision is intended to update the current framework and ensure consistency with Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, while taking account of developments since the last review in 2019. The Commission is also proposing to replace the existing Guidelines with a Commission Decision, giving the framework a stronger legal status. 

We welcome the initiative. But for Generation 2004, the key question is not simply whether the Commission has updated its rules. 

The real question is whether a colleague who reports wrongdoing will actually feel safe afterwards. 

A broader scope of protection 

The draft considerably broadens the categories of people covered. Protection would extend not only to officials and other statutory staff, but also to Temporary and Contract Agents, Seconded National Experts, trainees, service providers and their staff, candidates, and former staff, among others. 

The draft also expressly prohibits retaliation and identifies measures such as dismissal, negative appraisal, non-promotion, harassment, and non-renewal of contracts as possible forms of retaliation. Confidentiality rules are reinforced, and reporting channels — including direct reporting to OLAF — are clarified. 

These are important improvements. 

However, protection must not depend on a colleague being able to prove every aspect of their concern. A person who reports in good faith, with reasonable grounds for believing that the information is correct, should be protected even if some elements later prove to be inaccurate. 

The system should target malicious or knowingly false reporting, not honest mistakes. 

Protection must work in practice 

For Generation 2004, the most important issue is what happens after the report has been made. 

A colleague may be formally protected against retaliation, but retaliation can take many forms: a negative appraisal, non-renewal of a contract, professional isolation, removal of responsibilities or harassment. 

These measures can affect someone’s career immediately. 

Protection that arrives months later may come too late. 

This is why we raised the need for effective and rapid assistance, including interim protective measures where necessary. 

Direct access to OLAF must remain clear 

We also insisted that the new Decision must not create the impression that staff have to report wrongdoing to their hierarchy before contacting OLAF. 

The Administration confirmed during the meeting that staff may report directly to OLAF and that there is no requirement to approach management first. This is particularly important where the concern involves management itself. 

A question of trust 

Another concern is independence. Where allegations involve management or other senior colleagues, staff need confidence that their case will be assessed impartially and independently. 

Generation 2004 therefore called for stronger safeguards against conflicts of interest and for anyone implicated in the matter reported to be excluded from assessing the case. We also stressed that mobility, where used as a protective measure, must not become a punishment for the person who reported the problem. 

The whistleblower should not be the one who pays the professional price for speaking up. 

A change of culture is needed 

Whistleblowing should not be seen as a problem for the institution. A colleague who raises a genuine concern in good faith is contributing to the integrity and proper functioning of the European public administration. 

Staff should not have to choose between doing the right thing and protecting their career. This is particularly important for colleagues in less secure employment situations, who may understandably fear that speaking up could affect their contract or professional future. 

Generation 2004 therefore believes that the new framework should send a clear message: good-faith whistleblowing is a contribution to the institution and must never become a career disadvantage. 

What happens next? 

The meeting on 25 June was only the beginning. The discussion was limited to general principles, with the detailed article-by-article examination expected to resume in September. 

Generation 2004 will continue to push for a framework that provides: 

• effective protection against retaliation; 

• rapid and meaningful assistance; 

• clear access to OLAF; 

• independent and impartial assessment; 

• effective protection for all categories covered by the Decision; 

• safe confidentiality and anonymous reporting; and 

• a genuine culture of protection rather than fear. 

The Commission should not only have a whistleblowing policy that is legally compliant. It should have one that staff trust enough to use. 

For Generation 2004, the objective is therefore not simply a legally compliant whistleblowing framework, but a system in which staff — including colleagues in less secure or non-statutory positions — can report concerns without having to fear for their career, contract, or professional future. 

 

 

G2004 FOCUS | Article 24 — protection must be real 

Article 24 of the staff regulations provides a route for staff to request assistance when they face difficulties in the workplace. For whistleblowers, this can become particularly important when retaliation is alleged. 

Generation 2004 stressed that Article 24 must provide effective and timely protection, not simply a formal right to request assistance. 

During the meeting, concerns were raised about the effectiveness of the existing Article 24 system, including the high number of requests that do not result in an administrative inquiry. 

For a whistleblower facing a negative appraisal, non-renewal of a contract, professional isolation, or other retaliatory measures, waiting months for assistance may mean that the damage has already been done. 

We therefore support a fast-track procedure for urgent cases, together with interim protective measures and appropriate psychosocial support. 

Article 24 must be a credible protection mechanism — especially when a colleague has taken the difficult step of reporting wrongdoing. 

G2004 FOCUS | SNEs, trainees and service providers — protected on paper, but how in practice? 

The draft rightly extends whistleblowing protection to SNEs, trainees, service providers, and their staff, as well as other categories who may have access to relevant information. 

But Generation 2004 identified a potential gap: these colleagues do not necessarily have access to Article 24 of the Staff Regulations in the same way as statutory staff. 

This means that inclusion in the whistleblowing Decision could remain largely formal if there is no corresponding mechanism through which these colleagues can obtain assistance when retaliation occurs. 

We therefore called for the final text to clarify exactly what protection and assistance are available to these categories. 

Where Article 24 cannot apply directly, a complementary procedure should provide effective and equivalent protection. 

Protection should follow the person — not simply their administrative status. 

 

G2004 FOCUS | Direct access to OLAF 

Staff should not have to report wrongdoing to their hierarchy before contacting OLAF. 

The Administration confirmed during the meeting that direct reporting to OLAF remains possible and that staff are not required to approach their management first. 

This is particularly important where the concern involves a manager or where the reporting person does not feel safe using the hierarchical channel. 

Generation 2004 will insist that this principle is stated clearly and unambiguously in the final Decision. 

 

G2004 FOCUS | Retaliation can take many forms 

Retaliation is not limited to dismissal. 

The draft recognises measures such as: 

• non-renewal or termination of a contract; 

• negative appraisal; 

• non-promotion; 

• harassment; 

• removal or alteration of professional responsibilities; and 

• other measures that may disadvantage the reporting person. 

For Generation 2004, protection must therefore include career and contractual protection, not merely protection against formal disciplinary action. 

And where urgent risks arise, interim measures should be available before the situation causes irreversible damage. 

A whistleblower should never have to choose between speaking up and protecting their career.