Complaints Act: also applies to companies with 50-250 employees

Obligations to be fulfilled by 17 December 2023

Companies with more than 50 but fewer than 250 employees shall comply with the provisions of the Complaints Act as of December 17, 2023. We provide full support to meet the obligations.

In the following post, we provide an overview of the obligations imposed on companies operating with the above number of employees, as well as practical experience gained after the Complaints Act has entered into force.

Complaints Act: also applies to companies with 50-250 employees
2023. Nov. 14.

Introduction of the Complaints Act

It is well known that the Complaints Act has entered into force in the summer of 2023. Its aim was to made companies with more than 50 employees set up a so-called whistleblowing system, which would ensure the obligation to investigate unlawful or presumably unlawful conduct through a system which is essentially accessible to everyone, while maintaining the legal procedural guarantees.

In a post published before the legislation has entered into force, we had explained the obligations on employers – including

  • not just the setting up of the system itself,
  • but to provide clear and easily accessible information,
  • strict data protection rules,
  • and meeting extremely tight deadlines as well.

December 2023: deadline also for smaller companies

The obligations in question were initially imposed on companies with 250 or more employees and on companies carrying out activities specified in separate legislation until 24 July 2023, but from 17 December 2023, companies with more than 50 but fewer than 250 employees shall also comply with the legal requirements.

In the light of the above, we are already recommending, almost a month ahead of the deadline in December, to the companies concerned to start setting up a whistleblowing system in line with the legal provisions, or, if they have an existing system, to review it.

A time-consuming process: time to act!

In our experience, whether a company already has a respective, even global policy or not, implementing legal obligations is a time-consuming process. It requires the development of a system that fits into the day-to-day operations of the company in order to comply with the legal guarantees above and may therefore require internal consultations within the organisation to determine the most appropriate rules.

Of course, we are happy to provide advice and legal services for your company. Our office is also at your disposal during the revision of existing policies or the development of a completely new regulation. Please, contact us using the form below.

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Dr. Kékuti Ákos


Dr. Kovács-Vitek Brigitta



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