Act on the protection of whistleblowers in Greenland

On January 1, 2025, a new law on the protection of whistleblowers in Greenland comes into force. The law obligates all employers with more than 30 employees to introduce a whistleblower scheme.

In June 2024, Inatsisartut passed an Inatsisartut Act on the protection of whistleblowers in Greenland. The purpose of the Act is to protect people who disclose or publish matters of a critical or illegal nature in the company or organization of the employee. The Act enters into force on January 1, 2025, but it also applies to matters prior to the entry into force of the Act.

The law contains an extended burden of proof for employers who have dismissed, transferred, or significantly changed the work tasks of a person who has made a whistleblower report. This means that the employer must have a particularly good reason for dismissing, transferring, or significantly changing the work tasks of a whistleblower. Otherwise, it will be assumed that such actions are due to the whistleblower report.

The core of the law is found in Chapter 4 of the Act, according to which all public employers and private companies with 30 or more employees must establish an external whistleblower scheme. An external third party must be appointed to receive reports, follow up on reports, and provide feedback to the whistleblower. Group-affiliated companies can choose the same third party.

For workplaces with between 30 and 100 employees, the requirement to set up an external whistleblower scheme applies from June 1, 2025.

• January 1, 2025: Public employers and private employers with 100+ employees must be covered by an external whistleblower scheme.
• June 1, 2025: An external whistleblower scheme must cover private employers with 30-100 employees.
• Other private employers (

Both internal and external whistleblowing schemes apply:

• The scheme can be group-wide.
• Employers in the private sector can share resources in terms of establishment and operation.
• The impartial party must acknowledge receipt of the report within seven days.
• The impartial party must follow up on the report.
• The impartial party must provide feedback to the whistleblower within three months of confirmation.
• There must be written documentation of the establishment and procedures of the whistleblowing scheme.
• All reports must be recorded and documented.