At the end of 2021, a new legislation for the protection of whistleblowers was introduced, requiring all public sector employers and private companies with more than 50 employees to have a channel for reporting misconduct. When Universitetsläraren reviewed the reports for the first year three years ago, only a third of higher education institutions had received reports via their new channel.
The new review by Universitetsläraren includes reports to the whistleblowing channels at 33 colleges and universities from December 2022 to January 2026. During this period, 28 out of 33 higher education institutions received reports via their whistleblowing channels, and the number of reports has increased every year. In 2025, the number of reports was almost four times higher than in 2023, but only around 11 per cent of all reports during the period were deemed to fall within the scope of the whistleblowing legislation. Of the 33 higher education institutions, 17 have had whistleblowing cases that fall within the scope of the legislation; Stockholm University had the most cases with eight, followed by Lund University with six cases and the University of Gothenburg with five.
Malmö University has received the highest number of reports via its whistleblowing channel, with 98 reports received during the period following a significant increase in 2025. Only two of the reports received during the period were deemed to fall within the scope of the legislation.
The Whistleblower Act
The Whistleblower Act is a protective law based on an EU directive.
All public and private employers with at least 50 employees must have an internal whistleblowing function.
Whistleblowing reports must be handled by specially appointed persons.
Whistleblowers must be protected against reprisals. A whistleblower who is nevertheless subjected to reprisals is entitled to compensation.
For the protective legislation to apply, the matter must fall within the scope of the Whistleblower Act; for example, the misconduct must be of public interest.
The Swedish Work Environment Authority is the supervisory authority.
Source: The Swedish Work Environment Authority
Henrik Wiebe is a legal counsel at Malmö University and one of those authorised to handle reports submitted via the university’s whistleblowing channel.
“A whistleblowing report is a report made in a work-related context concerning irregularities with a public interest for disclosure,” he explains.
There must be reasonable grounds to believe that the information in the report is true, and the whistleblowing must also be submitted through the correct channel. As the whistleblowing must be in a work-related context, it primarily covers employees, but also volunteers, interns and others carrying out work under the organisation.
“For example, someone who is here working as a carpenter on our premises; if they find out something whilst working here, well, then they can report it to Malmö University. In that case, that person is covered by the law, as it is a work-related context.”
However, says Henrik Wiebe, it is misleading to say that a person who falls outside the law’s definition cannot blow the whistle.
“It’s just that the law provides protection, and in that case, you are not covered by that protection. But perhaps you don’t need it either, if you have no connection to the university.”
According to Henrik Wiebe, the reason Malmö University receives so many reports via its whistleblowing channel is that one individual with “a litigious attitude” is flooding the channel with complaints about the Swedish school system.
Is that allowed?
“There is no technical or legal way to prevent it. As our whistleblowing channel is meant to be open to volunteers, interns and the like, we cannot restrict access to an intranet.”
When a report is submitted to Malmö University’s whistleblowing channel, the appointed personnel jointly decide whether the report should be considered a whistleblowing case. Most cases fall outside the scope of the protection legislation for one reason or another, says Henrik Wiebe.
“Either because they have been anonymous, which makes it impossible to assess whether the information came to light in a work-related context. Or because the correct channel was not used.”
Whether or not a whistleblower should be able to remain anonymous is subject for recurring debate.
“When you read about these issues in the media, people say that it is a major problem that you cannot blow the whistle anonymously. And then I say, is it? Because it’s not that the authorities ignore reports submitted anonymously; it’s just that the person in question isn’t covered by the protection legislation. But if you’re anonymous, there’s no need for that anyway.”
An anonymous report is also much more difficult to investigate, says Henrik Wiebe. If a report is deemed to fall within the scope of the legislation, the appointed persons decide who should investigate the matter. According to standard procedure, the completed investigation is then referred to the university director – or, if the matter concerns them or their subordinates, to the vice-chancellor – who decides on any action to be taken. And, in accordance with the provisions of the law, the person who made the report is informed of the outcome.
Henrik Wiebe believes that the legislation itself is sound, but at the same time questions why a workplace as large as Malmö University has so few whistleblows.
“Not to say that we have problems, but there are always things that should be addressed. The fact that there are 84 cases in a year, but none is a whistleblowing case is, of course, not satisfactory.”
When asked whether he believes there is a fear behind the lack of whistleblowing cases, Henrik Wiebe is hesitant.
“I’ll leave it open as to whether it’s fear or a lack of knowledge about the protection legislation.”
One higher education institution that has not received any reports via its whistleblowing channel during the period is Karlstad University. Chief Legal Officer Eva Rendahl is one of two people authorised to handle whistleblowing reports at the university. She notes that there is both a whole lot and very little that can constitute a whistleblowing case, as the legal definition is not particularly clear, but that it concerns some form of misconduct.
“There must be a public interest in the matter coming to light. That, I would say, is the most important definition.”
In her capacity as chief legal officer, Eva Rendahl received enquiries and information regarding suspected irregularities even before the new legislation came into force, so she does not feel that the legislation has had any significant impact on how or when people contact her. Furthermore, she says there are many different channels for reporting various types of suspected irregularities at the university, such as disciplinary matters or research misconduct.
“An authority always has a responsibility to investigate what has happened. And that is certainly nothing that has changed with the legislation. The legislation is mainly about protecting the whistleblower; there is now an absolute requirement for confidentiality.”
Unlike at Malmö University, the whistleblowing channel at Karlstad University is located on the intranet.
“It is also intended for interns and similar staff, who gain access to our intranet.”
When a report is submitted via the whistleblowing channel, it is handled in accordance with the university’s procedure, which includes registration, documentation, an initial assessment and a response to the person making the report. Like at Malmö University, a whistleblower cannot be anonymous at Karlstad University.
”If you are to receive protection under the Whistleblower Act, you cannot be anonymous.”
However, Eva Rendahl points out that even though an anonymous report is not covered by the legislation, the information it contains must be taken seriously.
“The matter must be dealt with regardless. Whatever we call it, we have a responsibility to ensure that the authority conducts its business properly.”
