Glossary
Loi Sapin II
Loi n° 2016-1691 is the French anti-corruption law that includes whistleblower protections, updated by the Loi Waserman of 21 March 2022 to align with EU Directive 2019/1937. It requires French companies with 50 or more employees to operate an internal channel, acknowledge reports within 7 days, and respond substantively within 3 months.
Full definition
Loi Sapin II (named after then-finance minister Michel Sapin) was passed in 2016 and substantially amended on 21 March 2022 by the Loi Waserman to bring it into full alignment with EU Directive 2019/1937. The combined regime requires French companies with 50+ employees to operate an internal whistleblowing channel, acknowledge reports within 7 days, and respond substantively within 3 months. The Défenseur des droits supervises external reporting. Maximum criminal sanctions for obstruction or retaliation reach €60,000 plus imprisonment.
Related terms
- HinSchG The Hinweisgeberschutzgesetz is the German federal law implementing EU Directive 2019/1937. Passed on 12 May 2023 and in force from 2 July 2023, it applies to companies with 50 or more employees (since December 2023), is administered by the Bundesamt für Justiz, sets maximum fines of €50,000, and permits anonymous reporting.
- Ley 2/2023 Ley 2/2023 is the Spanish transposition of EU Directive 2019/1937, in force since 13 March 2023. It carries the EU's highest administrative fine ceiling at €1,000,000 for very serious infringements. Supervised by the Autoridad Independiente de Protección del Informante (AAI), it applies to private companies with 50 or more employees and all public-sector entities.
- National Transposition The national law that each EU member state enacts to implement EU Directive 2019/1937 domestically. A directive is not directly applicable: each state must pass its own law. States may exceed the minimum requirements (Spain set a €1m fine ceiling) but may not fall below them. All 27 member states had transposed Directive 2019/1937 by 2026.