Glossary

Reverse Burden of Proof

Under EU Directive 2019/1937 Article 21(5), once a reporter shows a protected disclosure followed by an adverse measure, the burden shifts to the employer to prove the measure was based on grounds unrelated to the disclosure. The mechanism matters because retaliation is hard to prove directly, and national courts in Germany, France, and the Netherlands have applied it since 2024.

Full definition

Under EU Directive 2019/1937 Article 21(5), once a whistleblower presents evidence of (a) a protected disclosure and (b) a subsequent adverse measure, the burden shifts to the employer to demonstrate that the measure was based on duly justified grounds unrelated to the disclosure. This is a substantial procedural advantage for reporters because retaliation is notoriously difficult to prove directly. National courts in Germany, France, and the Netherlands have already applied this reverse burden in dismissal disputes since 2024.

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