The purpose of the analysis was primarily preventive – to encourage municipalities to establish safe and effective internal mechanisms that allow individuals to report irregularities detected in their work environment without fear of retaliation, in accordance with the law.

Legal Background

ZZPri introduced a system of internal and external channels for reporting breaches of regulations and tied the right to protection and support measures to their proper use.

Local self-governing communities are required to set up an internal reporting channel regardless of the number of employees and to submit statistical data on internal reports to the Commission by 1 March each year.

Under the penal provisions of ZZPri, failure to establish an internal reporting channel constitutes a systemic offence overseen by the Commission.

According to Article 29 of ZZPri, an organisation may be sanctioned if it:

-          has not established an internal reporting channel as required,

-          has not described the procedure in its internal act, or

-          has failed to submit statistical data on internal reports to the Commission.

Liability may also extend to sole proprietors and responsible officials in legal entities, state bodies, or local self-government units.

As of 8 May 2025, 66 municipalities had not submitted the required statistical data for 2024, prompting the Commission to conduct a targeted review.

Methodology and Process

All 66 municipalities were contacted and asked to provide information on whether they had established an internal reporting channel, appointed a confidential person, and adopted an internal act defining the reporting process.

All municipalities responded. Most explained their failure to report by citing staff shortages or a lack of awareness that data must be reported even when no internal reports are received.

The Commission sent a notice to the Association of Municipalities of Slovenia (ZOS), the Association of Urban Municipalities of Slovenia (ZMOS) and the Community of Municipalities of Slovenia (SOS), requesting them to inform their members of the obligation to report statistical data under the ZZPri. The Commission later verified that the three municipal associations had informed their members about the reporting obligations and all three confirmed the distribution of the information to all municipalities, not only their members. ZOS and SOS also published the notice on their websites and included reminders in their regular newsletters.

Parallel to the analysis, misdemeanour proceedings were initiated in cases where violations of ZZPri were detected.

Findings

The analysis showed the following:

• 36 municipalities had a fully established internal reporting channel;

• 11 municipalities had an internal channel but with identified deficiencies;

• 19 municipalities had not yet established an internal reporting channel.

Municipalities with Established Internal Channels

36 municipalities were found to have fully implemented the internal reporting system as required by law.

The Commission issued reminders to these municipalities to fulfil their annual reporting obligation. By the completion of the analysis, 35 municipalities had submitted their 2024 data, while one (Šalovci) had not yet done so.

Municipalities with Identified Deficiencies

In 11 municipalities, certain shortcomings were observed — mainly the absence of a dedicated email address or phone line for receiving internal reports. Such arrangements are essential to ensuring confidentiality and trust in the system.

In two municipalities, the confidential person was also the director of the municipal administration, which may compromise the independence of the reporting mechanism. The Commission therefore recommended reconsidering such appointments.

By the end of the analysis, 10 municipalities had submitted their data, while one (Cerkno) had not.

Municipalities without Internal Channels

At the time of the analysis, 19 municipalities had not yet established an internal reporting channel, constituting a breach of ZZPri. Misdemeanour proceedings were launched against all of them.

The Commission also reminded municipalities to ensure that statistical data are submitted annually and within the statutory deadline, as failure to do so constitutes an offence under the penal provisions of the ZZPri, for which both the municipality and its responsible official may be sanctioned. Municipalities were invited to register their newly appointed confidential persons for the online training organised by the Commission in September 2025.

Conclusion

The analysis confirmed that the Commission’s preventive activities had a positive effect: following its intervention, the majority of municipalities established internal reporting channels and improved compliance with ZZPri.

Nevertheless, the findings highlight the need for continued awareness-raising and capacity-building, especially in smaller municipalities, to ensure that all local communities maintain secure, independent, and confidential mechanisms for reporting wrongdoing and comply with their statutory reporting obligations.