The Independent Authority for the Protection of Whistleblowers (AIPI) comes into operation
Since 1 September 2025, the Independent Authority for the Protection of Whistleblowers (AIPI) has been operating in Spain, created pursuant to Law 2/2023 and Directive (EU) 2019/1937. Its launch was formalised through Order PJC/908/2025, published in the Official State Gazette (BOE) on 12 August.
Among AIPI’s most significant responsibilities are:
- External reporting channel: this will serve as the national mechanism for receiving and processing reports of infringements in the private sector that affect more than one autonomous community. In cases of an exclusively regional scope, the designated regional authorities will intervene.
- Support and protection for whistleblowers: the authority will provide free advice, certification of protection against retaliation, and even financial or psychological support in exceptional situations. It may also promote precautionary measures such as job reassignment or paid leave.
- Sanctioning powers: it will have the capacity to impose penalties for non-compliance in the private sector, except in those autonomous communities that have expressly assumed this responsibility.
- Other functions: it will act as an advisory body to the Government, promote preventive measures, and cooperate with regional authorities to ensure uniform application of the law.
Impact on businesses
Companies must notify AIPI of the appointment of the Internal Reporting System Officer, regardless of whether they have already communicated this to the anti-fraud offices of the autonomous communities where their registered office is located. Although the Law set a period of ten working days, a transitional provision extends this deadline until 31 October 2025 for the first appointment. Subsequent dismissals or changes must be reported within the ordinary ten-day period.
Groups of companies that appoint a single officer for all group entities will only need to submit one joint notification, without the need to do so individually for each entity.
Companies are advised to review their internal reporting channels, remain aware of the coexistence of AIPI’s external channels and those of the autonomous communities, and adopt clear measures against retaliation towards whistleblowers.
It is essential to ensure compliance with Law 2/2023, particularly with regard to the infringements set out in Title IX, as AIPI will have the authority to impose state-wide sanctions.
