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AI companies can create a safer process for raising concerns by adapting established complaint or whistleblower procedures for AI-related issues, explaining exactly how reports are handled, and connecting each report to risk review, incident response, and remediation. The process should involve workers and relevant stakeholders, protect reporters only to the extent the company’s policies and applicable law allow, and distinguish internal concerns from regulatory complaints and legally defined serious-incident reports.
What a safe AI concern-reporting process needs to do
A reporting channel is useful only if people can understand how to use it and the company can act on what they report. OECD’s Due Diligence Guidance for Responsible AI, published on 19 February 2026, recommends developing or adapting staff complaint and whistleblower procedures for responsible-business-conduct concerns related to AI. It also recommends incident monitoring and response systems, broad decision-making, and stakeholder engagement that includes workers, their representatives, and trade unions.
Translate those recommendations into an operational path: a person submits a concern; an appropriate reviewer assesses urgency and scope; the issue is routed to the relevant risk, safety, compliance, or incident-response function; and the company considers corrective action and communicates appropriate follow-up. Make the path visible before a concern arises, not just after an incident.
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Make the route easy to find and use
Adapt a channel employees already know where practical, or clearly identify a dedicated route. Explain which kinds of AI-related concerns it accepts—for example, potential harms, unsafe behavior, misuse, or failures in oversight—without implying that a report must already prove a violation or incident. Specify whether the route is for employees only or also available to contractors, worker representatives, or other stakeholders.
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Offer appropriate alternatives where available and lawful: a manager, a specialist internal function, an independent reporting channel, or an external authority. Do not present the internal route as the only option when the circumstances or applicable law permit external reporting.
Be precise about anonymity and confidentiality
State whether anonymous reports are accepted, who can see identifying details, how those details are handled, and what limits apply. Do not promise absolute confidentiality or protection from retaliation unless the organization can support that commitment under its policies and applicable law. An anonymous channel may also limit the company’s ability to ask clarifying questions, so explain how a reporter can continue a conversation without disclosing their identity if the system supports it.
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Explain triage and follow-up
Tell reporters what happens after submission: who reviews reports, how urgent safety risks are escalated, whether the company may request more information, and what kinds of status updates or outcomes can be shared. Set expectations without guaranteeing a particular investigation result. Define an anti-retaliation policy and a way to raise concerns about retaliation, while making clear that protections depend on the organization’s commitments and relevant law.
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Every report should enter a process that can assess risk and trigger a proportionate response. Triage should identify whether the concern suggests imminent harm, a potential serious incident, a recurring control failure, or a lower-urgency issue needing further review. Route it to people with the relevant authority and expertise, record the assessment and decisions, and track any corrective actions to completion.
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The OECD guidance supports incident monitoring and response as part of responsible AI due diligence. The voluntary NIST AI Risk Management Framework offers a broader structure for that work through four functions: Govern, Map, Measure, and Manage. NIST does not prescribe a particular whistleblower-channel design; use the framework to situate reports within governance and risk work, not as a substitute for a reporting procedure. NIST says the framework is being revised, so check its current status when applying it.
Keep internal reports, complaints, and serious-incident notifications distinct
These routes serve different purposes. An employee may flag a possible risk before any incident occurs. A complaint to a regulator concerns an alleged infringement within that regulator’s authority. A legally defined serious-incident notification may impose specific obligations on a provider. A company process should help staff recognize and route these distinctions rather than treating every report as the same kind of case.
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EU AI Office Whistleblower Tool
The European Commission’s AI Act Whistleblower Tool is an external route for people professionally connected to providers of general-purpose AI models or certain AI systems within the AI Office’s enforcement remit. The Commission says people can submit anonymously, in any EU language, include supporting documents, and use a secure inbox for follow-up while preserving anonymity. It also describes internal procedures intended to protect whistleblowers’ identities. Check the tool’s current eligibility and remit before assuming a particular case is covered; it is not a universal channel for every AI concern, nor a replacement for an organization’s internal process.
EU complaints about AI systems
The AI Act Service Desk distinguishes the Whistleblower Tool from its AI systems Complaints Tool. The complaints route concerns alleged infringements involving systems within the AI Office’s exclusive competence; other systems may be handled by national competent authorities. The existence of either EU route does not mean the AI Office can address every complaint about an AI company or system.
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Serious incidents under Article 73
Article 73 concerns provider reporting of specified serious incidents involving high-risk AI systems to the relevant market-surveillance authority, or to the AI Office for matters within its scope. It also addresses timing rules tied to incident type and requires investigation, risk assessment, corrective action, and cooperation. The Service Desk’s Article 73 text is stated to be based on the consolidated AI Act as at 27 July 2026. Applicability and deadlines depend on the law and circumstances; check the current text and obtain appropriate legal advice before setting operational deadlines.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to assess reporting routes
If an organization has more than one route, compare them against the same practical questions. Publish the answers in plain language so workers can choose a suitable channel and understand its limits.
- Eligibility and scope: Who may report, and which kinds of concerns does the route cover?
- Ownership and independence: Is the route managed inside the organization or externally, and who has authority to review a report?
- Privacy: Are anonymous submissions possible? Who can access identifying information, and what confidentiality limits apply?
- Accessibility: What languages and submission methods are supported?
- Evidence and follow-up: Can reporters attach documents and continue communicating after submission?
- Action: How does a report reach risk assessment, incident response, and remediation?
- Legal and geographic scope: Which laws or authorities apply, and where?
For an internal process, these questions help expose gaps—for example, a nominally anonymous route with no secure way to answer follow-up questions, or a safety inbox that is not connected to the team responsible for incident response. For external channels, verify eligibility and jurisdiction directly with the relevant authority.
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