The Directive on the protection of persons who report breaches of Union law ((EU) 2019/1937) was published in the Official Journal of the EU (OJ) on 26 November 2019 and came into force on 17 December 2019. Member states have until 17 December 2021 to bring into force the laws, regulations and administrative provisions necessary to comply with the Directive.

Although Brexit means that the UK will leave the EU within the transposition timeframe and may not implement the Directive as such, it is nevertheless likely to be relevant in a number of ways.

This article considers where the requirements of the Directive differ from and/or impose additional obligations to the current requirements for financial services firms under UK law and the FCA's whistleblowing requirements.