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.

Figures checked against the statute text on October 25, 2026 by Cong Ho, editor of LawAsked.

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.

Protection from retaliation for reporting wrongdoing at work, by country
Country What is protectedRetaliation barredRemedy stated in the provision
Australia Exercising a workplace right, including making a complaint or inquiry about workplace law or one’s employmentAdverse 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 IIDismissal, 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 workBeing sanctioned, dismissed or discriminated against
Norway Reporting censurable conditions in the employer's business, internally, to authorities, or to the media on conditionsAny unfavourable act, practice or omission, including threats, harassment, demotion and dismissalRedress 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 43HAny detriment by the employer, co-workers or agents; dismissal of an employeeDismissal 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 provisionsDischarge or discrimination in compensation, terms, conditions or privilegesRelief 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
A person must not take adverse action against another person
Fair Work Act 2009, Section 340. Official text
is able to make a complaint or inquiry
Fair Work Act 2009, Section 341. Official text

Statute text as of October 21, 2026

Canada

Rule
Canada Labour Code s 147
No employer shall dismiss, suspend, lay off or demote an employee
has 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
Canada Labour Code, R.S.C., 1985, c. L-2, s. 147. Official text

Statute text as of October 21, 2026

France

Rule
Code du travail L1132-1 and L1132-3-3
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
Code du travail, Code du travail, art. L1132-1. Official text
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
Code du travail, Code du travail, art. L1132-3-3. Official text

Statute text as of October 23, 2026

Norway

Rule
Arbeidsmiljøloven §§ 2 A-1, 2 A-2, 2 A-4, 2 A-5
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
Arbeidsmiljøloven, Arbeidsmiljøloven § 2 A-1. Official text
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
Arbeidsmiljøloven, Arbeidsmiljøloven § 2 A-2. Official text
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
Arbeidsmiljøloven, Arbeidsmiljøloven § 2 A-4. Official text
kreve oppreisning og erstatning uten hensyn til arbeidsgivers eller innleiers skyld
Arbeidsmiljøloven, Arbeidsmiljøloven § 2 A-5. Official text

Statute text as of October 23, 2026

United Kingdom

Rule
Employment Rights Act 1996 ss 43A, 47B, 103A
a qualifying disclosure (as defined by section 43B) which is made by a worker in accordance with any of sections 43C to 43H
Employment Rights Act 1996, Section 43A. Official text
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.
Employment Rights Act 1996, Section 47B. Official text
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
Employment Rights Act 1996, Section 103A. Official text

Statute text as of October 25, 2026

United States

Rule
FLSA 29 U.S.C. §§ 215(a)(3) and 218c
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
Fair Labor Standards Act of 1938, 29 U.S.C. § 215. Official text
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 employment
may 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
Fair Labor Standards Act of 1938, 29 U.S.C. § 218c. Official text

Statute text as of October 21, 2026

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.

Use this data

Download the table as CSV

The table and the CSV are free to reuse under CC BY 4.0: credit LawAsked and link to this page. Quoted statute text stays under the terms of its official source.

How to cite this page

LawAsked, “Protection from retaliation for reporting wrongdoing at work, by country”, https://lawasked.com/guides/whistleblower-protection (reviewed October 25, 2026).

Important Legal Disclaimer

General legal information, not formal legal advice. The information provided on LawAsked does not constitute formal legal advice and creates no attorney-client relationship. If you require legal assistance, please consult a licensed attorney in your jurisdiction.