Protection from retaliation for reporting wrongdoing at work, by country
Only Norway and the UK have a dedicated whistleblowing regime in the ingested statutes, and Norway is the only one that sets out channels (internal, to authorities, to the media) and a compensation right in the labour act itself. France protects the status of lanceur d'alerte and witnesses to crimes inside its anti-discrimination articles, while the United States, Canada and Australia protect complaints and information given about a specific statute, such as the wage law or occupational safety, rather than wrongdoing in general.
Scope of this guide
Canada: the Canada Labour Code (federal sector) and the Ontario statutes that LawAsked has loaded. Other provinces are not compared.
United States: federal law only. State law is not compared.
| Country | What is protected | Retaliation barred | Remedy stated in the provision |
|---|---|---|---|
| Australia | Exercising a workplace right, including making a complaint or inquiry about workplace law or one’s employment | Adverse action against the person | |
| Canada | Testifying in a proceeding or inquiry under Part II, giving information about health and safety conditions, acting under or seeking enforcement of Part II | Dismissal, suspension, lay-off, demotion, penalty, withheld pay, discipline or threats | |
| France | Status as a lanceur d'alerte (whistleblower), facilitator or connected person; good-faith testimony about a crime or offence learned at work | Being sanctioned, dismissed or discriminated against | |
| Norway | Reporting censurable conditions in the employer's business, internally, to authorities, or to the media on conditions | Any unfavourable act, practice or omission, including threats, harassment, demotion and dismissal | Redress and compensation regardless of employer fault |
| United Kingdom | A protected disclosure: a qualifying disclosure made by a worker through one of the routes in sections 43C to 43H | Any detriment by the employer, co-workers or agents; dismissal of an employee | Dismissal for the disclosure is treated as unfair |
| United States | Filing a complaint, testifying or giving information about violations of the FLSA; under 218c, also reporting or objecting to violations of the health-reform provisions | Discharge or discrimination in compensation, terms, conditions or privileges | Relief through the procedures and remedies of 15 U.S.C. § 2087(b) (for § 218c) |
Country by country
Australia
- Rule
- Fair Work Act 2009 ss 340-341
- This is general protection for workplace rights, not a dedicated whistleblower law about wrongdoing in general. Whistleblower rules for corporate and public-sector disclosures sit in other Australian acts that are not ingested. The remedies are in other parts of the Act and are not quoted here.
A person must not take adverse action against another person is able to make a complaint or inquiry Canada
- Rule
- Canada Labour Code s 147
- Federal-sector employers only. The quoted prohibition covers rights under the health and safety Part; it is not a general whistleblower law. Complaints about breaches are made to the Board under section 133, which is not quoted here.
No employer shall dismiss, suspend, lay off or demote an employeehas provided information to a person engaged in the performance of duties under this Part regarding the conditions of work affecting the health or safety of the employee or of any other employee of the employer France
- Rule
- Code du travail L1132-1 and L1132-3-3
- The protection sits in the anti-discrimination chapter and refers to the 2016 law on transparency and anti-corruption for the definitions and further protections; that law is not ingested, so the channels and remedies are not summarised.
aucun salarié ne peut être sanctionné, licencié ou faire l'objet d'de sa qualité de lanceur d'alerte, de facilitateur ou de personne en lien avec un lanceur d'alerte Aucune personne ayant témoigné, de bonne foi, de faits constitutifs d'un délit ou d'un crime dont elle a eu connaissance dans l'exercice de ses fonctions ou ayant relaté de tels faits ne peut faire l'objet des mesures mentionnées à l'article L. 1121-2 Norway
- Rule
- Arbeidsmiljøloven §§ 2 A-1, 2 A-2, 2 A-4, 2 A-5
- Employees and hired-out workers are covered. Reporting that concerns only the employee's own employment relationship is not whistleblowing under the chapter unless it also falls within the listed censurable conditions. Reporting to the media or the public needs good faith, a matter of public interest and prior internal reporting or reason to think it would not help.
- If the employee presents information suggesting retaliation, the employer must show that it did not happen.
Arbeidstaker har rett til å varsle om kritikkverdige forhold i arbeidsgivers virksomhet.Ytring om forhold som kun gjelder arbeidstakers eget arbeidsforhold regnes ikke som varsling etter kapitlet her Arbeidstaker kan alltid varsle eksternt til en offentlig tilsynsmyndighet eller en annen offentlig myndighet.arbeidstaker først har varslet internt, eller har grunn til å tro at intern varsling ikke vil være hensiktsmessig Gjengjeldelse mot arbeidstaker som varsler i samsvar med §§ 2 A-1 og 2 A-2, er forbudt.må arbeidsgiver sannsynliggjøre at det likevel ikke har funnet sted slik gjengjeldelse kreve oppreisning og erstatning uten hensyn til arbeidsgivers eller innleiers skyld United Kingdom
- Rule
- Employment Rights Act 1996 ss 43A, 47B, 103A
- Workers, including some agency and other non-employee workers under section 43K, are covered against detriment. For employees, dismissal is handled under section 103A rather than section 47B, and the qualifying-disclosure definition in section 43B is not quoted here.
a qualifying disclosure (as defined by section 43B) which is made by a worker in accordance with any of sections 43C to 43H A worker has the right not to be subjected to any detriment by any act, or any deliberate failure to act, by his employer done on the ground that the worker has made a protected disclosure. shall be regarded for the purposes of this Part as unfairly dismissed if the reason (or, if more than one, the principal reason) for the dismissal is that the employee made a protected disclosure United States
- Rule
- FLSA 29 U.S.C. §§ 215(a)(3) and 218c
- Federal law only, and only the FLSA protections are ingested. They cover complaints about wage and hour violations and, in § 218c, the Affordable Care Act amendments, not wrongdoing in general. Other federal whistleblower laws are not ingested. The rights in § 218c cannot be waived by agreement.
to discharge or in any other manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this chapter No employer shall discharge or in any manner discriminate against any employee with respect to his or her compensation, terms, conditions, or other privileges of employmentmay seek relief in accordance with the procedures, notifications, burdens of proof, remedies, and statutes of limitation set forth in section 2087(b) of title 15 Countries not in this table yet
Germany, Spain, Austria, the Netherlands, Sweden and Japan are left out because their whistleblower statutes (for example the German Hinweisgeberschutzgesetz and the Japanese Whistleblower Protection Act) are not among the ingested acts. A search of the ingested labour acts did not find an equivalent provision.
How this table was built
Every row is taken from the official, consolidated text of the statute, which LawAsked loads from each government’s legislation service.
Each figure is tied to a passage quoted word for word from that text. When the page is served, it checks that every quoted passage is still in the current text of a law that is in force; if a law is amended and its wording changes, that row is hidden until a person reviews it again.
The table shows the statutory minimum only. Collective agreements, awards and individual contracts often give more than the statute, and some countries let a collective agreement set different terms.
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LawAsked, “Protection from retaliation for reporting wrongdoing at work, by country”, https://lawasked.com/guides/whistleblower-protection (reviewed October 25, 2026).
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