On September 1, 2025, Spain will launch the country’s new independent whistleblower protection authority - Autoridad Independiente de Protección del Informante (AIPI). This is part of the implemention of Law 2/2023 This law generally applies to companies of 50 employees or more although there are nuances and caveats in the scope of application. Companies do not necessarily have to be domiciled in Spain to fall within scope - it also applies to foreign-registered companies operating in Spain. If you are unsure if you are within scope of the law then the advice is to check.
The AIPI brings in new new obligations regarding internal reporting systems and the designation of responsible officers.
From 1 September, companies in scope will have two months to notify the AIPI of the appointment or removal of their designated internal reporting system officers. Although the law does not yet specify the format or platform for these notifications, it is expected that the AIPI will issue operational guidance shortly after its launch.
The AIPI is designed to be a central enforcement and support body with broad powers, including:
- Managing the external reporting channel for whistleblowers.
- Providing protection and support to individuals who report misconduct.
- Initiating and resolving sanctioning procedures for violations of Law 2/2023.
- Issuing circulars and recommendations to guide best practices in whistleblower protection and compliance.
- Developing public sector crime prevention models, which may influence private sector compliance standards
Source - Baker McKenzie blog on Lexology site
