The classic trap
Recital 75 imposes an active transparency obligation on competent authorities, but it directly affects private organisations that must inform their employees of available internal AND external channels. In Luxembourg, the OFRS and sectoral authorities (CSSF, CNPD, ITM, CAA, ILR) publish their procedures, but an organisation that fails to relay this information in its internal regulations or intranet exposes its internal channel to systematic bypass: whistleblowers will go directly to the external authority or, worse, to the press, qualifying for public disclosure under Article 15 of the directive.
The 6 pieces of information that must appear on your dedicated internal page
- Identity and contact details of the person or department in charge of handling reports (reporting officer, DPO if applicable).
- Description of the internal channel (online form, phone line, physical appointment) with confidentiality guarantee and anonymity option.
- Exhaustive list of competent external authorities in Luxembourg (OFRS, CSSF, CNPD, ITM, CAA, ILR) with direct links to their forms.
- Legal deadlines: acknowledgement of receipt within 7 days, feedback within 3 months maximum.
- Protection measures against retaliation and civil and criminal remedies (Law of 16 May 2023).
- Conditions for public disclosure (Article 15) to prevent employees from bypassing the system through ignorance.
How Luxgap automates this risk
Our Luxgap Whistleblowing Transparency Hub transforms the informational obligation of recital 75 into a living, multilingual and legally enforceable intranet page, automatically updated whenever a Luxembourg authority changes its procedure. The tool continuously monitors the websites of the OFRS, CSSF, CNPD, ITM, CAA and ILR via an AI agent that detects changes in forms, deadlines or contact details and propagates the information to your internal portal without human intervention.
- Generates a multilingual /reports/ page (FR, EN, DE, LU, PT) compliant with Article 7 of the Law of 16 May 2023, with automatic updates of external authority contact details.
- Detects procedural changes published by the OFRS and sectoral regulators in less than 24h and alerts the reporting officer via Teams or email.
- Measures employee consultation rate of the page via an embedded pixel and produces a quarterly report demonstrating the effectiveness of the information.
- Publishes a pre-drafted annex to internal regulations describing internal channels, deadlines and guarantees against retaliation.
- Produces a timestamped and cryptographically sealed PDF attesting that, on a given date, the information was accessible to employees, enforceable in labour or criminal litigation.
- Integrates an end-to-end encrypted reporting form, hosted in Luxembourg, with automatic acknowledgement of receipt within 7 days.
Available as a complement to a Luxgap DPO or CISO mandate or as a dedicated SaaS module depending on your scope. Request a personalised quote and our teams will prepare a demonstration on your actual intranet, with a free 48h blind audit to measure your exposure before any commitment.
