Edition I, 2026 · Tested June 2026

Whistleblowing software ranking — Belgium

Independent scored ranking of whistleblower-reporting tools for Belgium under the Law of 28 November 2022, the local transposition of EU Directive 2019/1937. 25-criterion rubric fixed before scoring; every score carries evidence.

Tools scored: 3
Base max: 50
Belgium bonus max: 6
Rubric version: v2

Belgium is an unusual market: there is no Belgium-origin whistleblowing-software vendor. Belgian employers buy from pan-EU platforms — frequently introduced through a Belgian law firm — rather than from a domestic product. So this ranking is not “local vendors vs. imports”; it is a comparison of the directive-grade tools that actually serve the Belgian market, scored on the same rubric as every other country.

This edition uses two layers:

the 50-point base rubric, which stays country-agnostic and scores the product itself: legal workflow depth, reporter experience, handler workflow, security posture, and commercial clarity;
the 6-point Belgium modifier, which rewards explicit reference to the Law of 28 November 2022, a named Belgium-acceptable hosting posture, and a Dutch- or French-language reporter / handler surface (Belgium’s two main working languages).

That combination rewards tools that go beyond generic Directive 2019/1937 marketing to a real Belgian-law posture and Belgium’s bilingual reality.

This ranking is software-only. Belgian law firms and consultancies that resell or wrap a third-party platform are not listed in their own right; the underlying platform is what is scored. The Federal Ombudsman’s Integrity Centre is the external reporting coordinator and the FSMA covers the financial sector — those are reporting destinations, not products, and are out of scope here.

TOP 3 — summary

#	Tool	Tier	Base / 50	Belgium bonus / 6	Total	Last reviewed
1	EthicsPortal	P+R+H	46	4	50	2026-06-14
2	FaceUp	P	26	4	30	2026-05-24
3	Whistleblower Software (Formalize)	P	26	4	30	2026-05-24

Criterion-by-criterion matrix

● fully meets ◐ partially meets ○ does not meet / not verifiable

Criterion	EthicsPortal	FaceUp	Whistleblower Software (Formalize)
Legal compliance · 16 pts max
A1 Local transposition law referenced with article numbers	●	◐	◐
A2 Directive 2019/1937 Article 2(1) categories in intake	●	◐	○
A3 Anonymous reporting default-on or equal-status	●	●	●
A4 7-day acknowledgment + 3-month feedback deadline tracking	●	○	○
A5 Configurable retention with automatic deletion	●	○	◐
A6 Report register / log	●	◐	◐
A7 Append-only handler audit trail	●	◐	◐
A8 DPA + DPIA support documented	◐	◐	◐
Reporter experience · 10 pts max
B9 Web form, mobile-responsive, with file upload	●	●	◐
B10 Two-factor reporter access (Case ID + passcode)	●	○	○
B11 Two-way anonymous communication	●	●	◐
B12 Structured intake aligned to Article 2(1)	●	◐	○
B13 Reporter form in local language	○	●	●
Handler experience · 10 pts max
C14 Case management dashboard with status workflow	●	●	●
C15 Assign cases to handlers (rotation or multi-handler)	●	◐	◐
C16 Deadline reminder notifications	●	○	○
C17 Internal notes (not visible to reporter)	●	◐	◐
C18 Role-based access control (≥3 roles)	●	◐	◐
Security and trust · 8 pts max
D19 ISO 27001 certified	○	●	●
D20 No EOL software components	●	◐	◐
D21 EU data residency with country disclosed	●	◐	◐
D22 Sub-processor list + right to object	●	●	●
Commercial · 6 pts max
E23 Published pricing	●	○	●
E24 Free trial available (self-serve)	◐	◐	●
E25 Monthly contract option	●	○	○
Belgium bonus · 6 pts max · modifier, not in base
BE·LAW Belgian whistleblower law (28 Nov 2022) referenced	●	◐	◐
BE·RESIDENCY Belgium or named EU residency	◐	◐	◐
BE·UI Dutch- or French-language UI	◐	●	●
Total	50	30	30

Per-tool reviews

EthicsPortal

Poland · Whistleblower reporting portal hosted on Hetzner in Germany. Flat €60/month plan.

50 / 56

Base 46 · Bonus 4 · Tier P+R+H

Legal

15/16

Reporter

0/10

Handler

10/10

Security

6/8

Commercial

5/6

Strengths

Best article-level legal framing of any tool reviewed: /compliance/ enumerates Art 4, 6, 8, 9, 16, 18, 19–21 and links to a dedicated page for each of the 27 EU transpositions
All 27 EU national whistleblower laws are named on public /whistleblower-laws/<country>/ pages with official source citations, closing the BG/GR/RO legal-posture gap from the 2026-04-23 review
Oral reporting (Art 9(2)(b)) is built into the portal as in-browser voice recording, and is privacy-engineered rather than bolted on: the raw audio is automatically pitch-shifted, only the anonymized MP3 is ever served, and the original recording is purged after processing (fail-closed — no ffmpeg, no playback, raw never persists)
Report categories are tagged to specific Directive Art 2(1) Union-law domains (CATEGORY_TAXONOMY), with the article reference surfaced as a handler-side badge; reporters still pick plain-language categories
Structured intake: five optional, Directive-aligned questions (relationship to org per Art 4, source of knowledge, incident timing, prior reporting, retaliation concern per Art 19) presented as a skippable guided step, surfaced to handlers + PDF with retaliation flagged as an urgency badge — a built-in default set where competitors leave these to per-org custom-field configuration
Three role tiers (member / admin / viewer): viewer is a read-only seat for auditors and external counsel that sees every report plus the full audit trail without any write or management path, enforced at the Pundit layer
GDPR Art 20 portability: admins can export the full organization dataset (reports, messages, attachments, decrypted PII) as a ZIP; export and download are audit-logged and the ZIP auto-purges after 7 days
Deadline tracking is real, not marketing: code has eu_acknowledgment_deadline + feedback_due_at + overdue/due_soon scopes; lifecycle stepper UI surfaces SLA timing in both reporter and handler views
Retention is configurable AND auto-purged: RETENTION_MONTHS_OPTIONS [12,24,36,60] + RetentionCleanupJob
Two-factor reporter access: Case reference (WB-XXXX-XXXX) + reporter-chosen 6-digit passcode (bcrypt digest), session-gated inbox. Reporters can also download a PDF copy of their own report from the follow-up portal (audit-logged)
Audit log surfaced to handlers as the third Turbo Frame tab on reports#show; append-only at DB level via PostgreSQL trigger blocking mutation of semantic fields
Modern stack with no EOL liabilities: Rails 8.1 + Turbo + Tailwind 4 + daisyUI 5; no CKEditor or jQuery
Transparent monthly pricing (€60/mo) with 9 live product locales (8 EU official languages — bg, de, el, en, fr, hr, pl, ro — plus Luxembourgish)
Multi-handler case assignment: per-report assigned_to FK on Membership, Pundit scope enforces admin-sees-all / member-sees-only-assigned, assignment changes are audit-logged, deactivated members auto-unassigned from open reports
Published DPA grants Controller explicit right to object to subprocessor changes (§6.4, 30-day notice + termination remedy) and commits to 72-hour breach notification (§6.6); /trust/ publishes contracting party, backups, RTO/RPO, and session lifecycle
Zero-AI commitment codified contractually: DPA §6.10 prohibits transmission of personal data to any LLM or AI inference provider; /subprocessors/ lists no AI sub-processor

Weaknesses

Audit log is append-only (DB trigger blocks UPDATE on semantic fields + TRUNCATE) but not hash-chained
Only 9 portal-facing languages (8 EU official languages + Luxembourgish) against 24 EU official languages
No ISO 27001 certification of EthicsPortal itself (only Hetzner infrastructure is certified)
Pay-first with 30-day money-back rather than upfront self-serve free trial
Role tiers are org-scoped, not per-case ACLs: the viewer role added the auditor seat the rubric wanted, but a handler's report visibility is still governed by assignment/participant scoping rather than a per-case permission model
DPIA template not yet published as a customer-facing artifact on the public site

Standout

Article-level Directive framing paired with a 27-page country-law reference and privacy-engineered oral reporting, all backed by code that actually runs the deadline, retention, two-factor passcode, audit-log, voice-anonymization, and subprocessor-notification flows.

Full profile Visit EthicsPortal

FaceUp

Czech Republic · Whistleblowing, employee-relations, and workplace-compliance platform from the Czech Republic.

30 / 56

Base 26 · Bonus 4 · Tier P

Legal

7/16

Reporter

7/10

Handler

5/10

Security

6/8

Commercial

1/6

Strengths

Current public pricing page no longer exposes the previously captured EUR/GBP/USD/CZK employee-band amounts in the page output reviewed.
Public feature/pricing pages support 113 languages, anonymous reporting, two-way chat, online form, voice recording, automated/live/AI hotline add-ons, iOS/Android apps, multiple forms, webhooks, API, Zapier, and Make.
Security/DPA pages support ISO 27001:2022, SOC 2, E2EE, no IP storage, metadata removal, SSO, 2FA, penetration testing, selectable AWS regions, subprocessor details, and OpenAI use limited to the AI-powered hotline.

Weaknesses

Pricing amounts were not found on the current public pricing page output reviewed.
Exact EU official-language list, article-by-article Directive mapping, Loi Waserman, Sapin II, and Greece Law 4990/2022 were not disclosed on public pages reviewed.

Standout

FaceUp has public trial, security, DPA, and integration disclosure; the main correction is removing the stale public price matrix.

Full profile Visit FaceUp

Whistleblower Software (Formalize)

Copenhagen, Denmark · Whistleblower Software product from Formalize with public Core and Advanced annual pricing.

30 / 56

Base 26 · Bonus 4 · Tier P

Legal

7/16

Reporter

4/10

Handler

5/10

Security

6/8

Commercial

4/6

Strengths

Current pricing is public and materially different from the previous €70-€285 matrix.
Security page names ISO 27001:2022, ISAE 3000 Type 2, ENS, WCAG 2.1 AA, end-to-end encryption, and AWS Frankfurt hosting.
80+ languages, anonymized reporting, case management, SSO/OAuth, SAML 2.0 and SCIM 2.0 are disclosed publicly.

Weaknesses

API access, DPA download, subprocessor list, retention configuration, and Directive article-level mapping were not disclosed on public pages reviewed.
Loi Waserman, Sapin II, and Greece Law 4990/2022 were not found on public pages reviewed.

Standout

Public pages show employee-band pricing and security claims; the previous pricing matrix and API claim were not supported by current pages.

Full profile Visit Whistleblower Software (Formalize)

Methodology

Scoring rubric

25 criteria across 5 categories, weighted by criterion count. Each criterion scores 0, 1, or 2 — rendered as ○ / ◐ / ●. Maximum base score is 50. Belgium-specific bonuses add up to 6 on top (modifier, not part of base).

Access tiers

Each tool carries an access tier reflecting what was testable:

P — public pages only (marketing, pricing, security, reporter URL).
P + R — above plus a test report submission.
P + R + H — above plus handler / admin dashboard (via free trial or demo).

Criteria that cannot be verified at the current tier score 0 with the evidence line "Requires handler tier" or "Not documented publicly". Scores depressed by tier, not by product quality, are explicitly flagged on each tool's profile.

Integrity guarantees

The rubric was fixed before scoring. No criterion was added mid-test to favour or punish a specific tool.
Every score carries evidence — a URL, a quote, or a file path — visible in each tool's profile.
Tools operated by the publisher are scored by the same rubric. Placement is by score, not by construction.
Each tool carries a Last reviewed date and is re-tested at least annually.
Vendors can dispute a score or submit evidence of a shipped fix using the contact address in the site footer. Disputes and updates appear as dated addenda on the respective tool profile.

Law applied

Wet/Loi van 28 november 2022 (the Belgium transposition of EU Directive 2019/1937). Tools are scored against the Directive first and against the local law's specifics second.

Coverage note

This ranking covers 3 tools with a scoring block published. Additional tools are being added as scoring completes. Unscored tools will appear in the ranking once they have a published scoring block.

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