Looking Back, Moving Forward: A 15-Year Journey in Whistleblowing and Incident Management Benchmarking – What’s Next?

Predictions for 2026: what’s on the horizon?

Internal reporting is here to stay

More than 80% of professionals surveyed globally for our 2025 State of Risk & Compliance Report said employees were most likely to make a report internally versus to an external entity (or simply to not make a report in the first place). This is remarkable validation for the embrace of internal reporting programs as cited by nearly 1,000 practitioners in compliance, risk, legal, human resources and other related fields.  

Our long-term customer internal reporting data also shows the embrace of internal reporting programs is only increasing. In 2008/2009, organizations received a median 0.9 Reports per 100 Employees. Our latest report, which examines data from 2024, found a global median of 1.57 Reports per 100 Employees. That’s nearly a 75% increase in reporting levels. 

Often, reporters simply want to see a problem fixed and they want their management team to handle it. This is despite some instances when the whistleblower programs of external entities such as the United States Securities and Exchange Commission may offer incentives – monetary rewards – for certain substantiated cases. Reporters continue to see internal reporting programs as the go-to channel to most efficiently raise and address concerns. 

These increasingly engaged reporters will also expect results. Median Case Closure Time has decreased from 32 days in 2009 to 21 days in 2024 – reporters in 2026 will be more likely to consider these sorts of metrics to be “the norm,” and organizations falling behind these trends will find themselves challenged to engage employees in embracing a culture of ethics and trust in internal reporting.  

What does this mean for 2026? While our data suggests the possibility that internal reporting rates may be reaching a plateau, they have increased quite substantially in the long term. Employees and third parties will increasingly expect organizations to have robust channels through which to report misconduct and make inquiries without fear of retaliation. And where those channels fall short, employees – along with customers, regulators and others – will notice. 

Be prepared for more reports of retaliation

Allegations of retaliation carry special weight among the categories of misconduct and should be tracked, managed and reported with special attention. Retaliation for making a report – or simply the fear of it – disincentivizes reporting in the first place. Misconduct goes unrecognized and unmitigated. Risk grows, perhaps unknown to those who manage it. Employees lose trust that their organization will do the right thing.  

Thankfully, reporters are speaking out a bit more about retaliation. In 2009, 0.62% of all reports pertained to retaliation. In 2024, the median share was 3.08%. That said, research done by the Ethics and Compliance Initiative has shown that far more employees say they have experienced retaliation than those who report it. Organizations should not assume that few reports of retaliation mean it isn’t happening and need to take proactive steps to prevent and detect it. 

Of particular concern, the Substantiation Rate for retaliation reports lags far behind overall Substantiation Rate, but it is improving ever so slightly. In 2009, median Substantiation Rate for retaliation reports was 11%. It reached a high point of 27% in 2014 but has been below 20% ever since. Noting that the overall Substantiation Rate for all cases in 2024 was 46%, there is much more work to do to better identify and resolve retaliation cases.  

In perhaps our most shocking finding this past year, approximately 45% of substantiated retaliation cases did not result in discipline or employment separation – and almost 14% resulted in no action. Lack of response to validated retaliation reports transfers non-retaliation policies to the paper program list. 

In 2026, organizations need to foster better understanding of a no-tolerance policy for retaliation. Our industry has spent decades pressing this point, and after long efforts, employees are starting to come to the table ready to call out retaliation. Organizations without clear policies, messaging, and action around anti-retaliation in 2026 will fall behind.

Report quality is going up 

It’s surprising to consider the overall Substantiation Rate was at a median 29% in 2009, and in 2024, 46%, as noted above. This is a huge improvement, and the latest in a long-term, generally upward trend. It may be safe to assume organizations are doing a better job educating potential reporters about what constitutes actual misconduct and inviting more context to inform quality investigations. 

For 2026, the bar will be set even higher. Companies need to offer more in-depth training, easy access to policies, and ongoing reinforcement of their values to keep improving the quality of reports they receive. Reporters are starting to expect this level of support—and may hesitate to step forward if it’s not there. 

‘Workplace Civility’ is getting noticed 

While representing a relatively newer category of misconduct for the purpose of NAVEX analysis, the Workplace Civility category – reports related to abusive or disrespectful behavior connected to work that are not harassment or discrimination – is becoming a key risk area. As explored elsewhere in this Top 10 Trends in Risk & Compliance Report, this is another misconduct category (or, in our words, Risk Type) worthy of special note as an indicator of the hard-to-define risks behind fostering a healthy workplace culture. 

As recently as 2021, Workplace Civility reports represented a median of 15.8% of all reports – one of the highest Risk Types in our report. That median has only become larger – at 17.7% of reports in 2025.   

For 2026, this trend is worthy of some serious contemplation. Reporters appear to be more comfortable using internal reporting systems to elevate concerns about all sorts of issues. Workplace Civility-type issues are inherently nuanced but may provide some of the richest indicators of culture and risks facing a given organization. We expect these reports to continue to represent a significant share of all reports in 2026 – and organizations that pay attention to these reports will learn much about their cultures and risk management. 

More people are putting their names on reports 

Looking back to 2009, a greater share of reporters today are willing to put their name behind an allegation. This is a boon for investigations by providing more context to allegations, and a signal that some reporters increasingly trust they will not face retaliation for raising concerns about misconduct. A median 65% of reports were anonymous in 2009, and in 2024, 54%.  

For 2026, anonymous reporting remains a key part of any internal reporting program. In general, anonymous reporting seems to have leveled off in the mid-fifty percent range, but we note that organizations continue to receive a higher percentage of web reports which are more likely to be anonymous. With anonymous reporting remaining steady, this may represent an increased expectation of protection from retaliation, one that organizations should continue to uphold. 

Report outcomes showing higher than expected ‘no action’ 

Over the past 15 years, we have broadened the range of metrics we examine to provide greater insight into the “how and why” of reporting. One newer set of metrics is on report outcomes. What happens as a result of a substantiated case? While it is encouraging to observe that many reports are being treated with the seriousness they deserve, a significant concern remains: close to 15% of substantiated cases do not result in any follow-up action – no training, no policy change, no coaching, and no meaningful discipline. And – 14% of substantiated retaliation cases result in no action. 

When this occurs, individuals may question the value of reporting issues or whether needed change will occur. For organizations seeking to build trust in their reporting systems and encouraging employees to speak up, it is essential to identify the reasons behind this lack of response and ensure that concerns are effectively addressed—otherwise, morale may suffer, and the reporting process itself could be undermined. For 2026, organizations will want to track this metric closely. 

Archives reveal other notable trends  

In perusing the old reports we found other notable changes we can consider for our future programs. For example, in 2008, 43% of anonymous reporters followed-up on their report in the system – close to half. Now, we barely pass 25%. Why have so many employees chosen to step back once they have filed a report?  

Further, while we think we are receiving a lot of Workplace Conduct reports now, in 2008, human resources related cases were 70% of the reports. And finally in a sign of the times, in 2008, 15% of the reports were submitted via the web (which actually is surprisingly high). In 2024, the median of web reporting was 58%. We expect web reporting to continue to grow in share.

Conclusion

These are some of the key trends we’ve spotted over the past 15 years. If you’re a regular reader of our report, you know we’re always digging deeper and finding new ways to make sense of the data. Point-in-time benchmarking is still valuable, but looking at the long game reveals even more insights and opportunities to improve – and plenty of reasons to be optimistic about the future. It has been an honor for me to have been involved in preparing each one of these 15 reports. 

2026 prediction

In 2026, employees, third parties, and everyone else involved will have a clearer sense of what strong internal reporting programs look like – and they’ll continue to expect more. That means easier reporting, strong protection from retaliation, and real results with appropriate actions taken. Advances in case data analytics will further enable organizations to spot trends and risk areas faster and more easily. Are you ready for what’s next? 

This article is part of our 2026 Top 10 Risk & Compliance eBook. Check out the full eBook for more expert predictions for the year ahead.