As part of its advocacy efforts towards building a people-centered and sustainable recovery from the Beirut port explosion and its endeavors to promote inclusive and equitable social justice, as well as foster trust between individuals, entities, and the Lebanese government, the Lebanese Center for Policy Studies (LCPS) partnered with Transparency International (TI) and its local chapter, Transparency International Lebanon – No Corruption, to issue “The Reform Monitor.” The topics covered by the monitor are linked to the areas of reform, recovery, and reconstruction (3RF). The monitor falls within the Building Integrity and National Accountability in Lebanon (BINA’) project, which is funded by the European Union. The views expressed in the monitor do not necessarily reflect those of the donor.

Lebanon continues to grapple with pervasive corruption that undermines public trust, distorts the rule of law, and drains critical state resources. In this context, whistleblower protection mechanisms play a crucial role by enabling individuals to share evidence of wrongdoing with minimal personal risk. Parliament has enacted several legislative measures intended to safeguard and incentivize those who expose corruption, most notably the Whistleblower Protection Law (Law No. 83/2018) [1], further amended in 2020 to broaden avenues for disclosure. Yet legal gaps, budgetary constraints, and coordination challenges persist. This article provides a detailed legal assessment of Lebanon’s whistleblower framework, identifies key deficiencies, and proposes solutions that align with international best practices.

What’s the issue at hand?

​For decades, corruption has been recognized as a root cause of Lebanon’s multiple governance crises. According to Transparency International's 2024 Corruption Perceptions Index, Lebanon received a score of 22 out of 100, ranking 154th among 180 countries, underlining the severity and persistence of the problem [2]. Public trust in state institutions has consequently eroded, and multiple international stakeholders including the IMF have emphasized that Lebanon must strengthen its anti-corruption framework to qualify for financial assistance [3].

Whistleblower protection represents a cornerstone of modern anti-corruption efforts. It ensures that individuals aware of unlawful or unethical practices can safely disclose vital information without fear of reprisal. This approach aligns with Lebanon’s commitments under the United Nations Convention against Corruption (UNCAC) [4], which urges States Parties to encourage persons with knowledge of corruption to report these acts. In Lebanon, that commitment took shape through Laws No. 83/2018 and No. 182/2020, accompanied by the establishment of the National Anti-Corruption Commission (NACC) under Law No. 175/2020. While these developments represent significant legislative progress, implementation hurdles have limited their effectiveness.

Legislative and Institutional Framework

The Whistleblower Protection Law serves as a legal foundation for safeguarding individuals who voluntarily disclose acts of corruption. It mandates protection against workplace retaliation and was intended to offer potential rewards for substantial evidence leading to the prosecution of corrupt actors. However, whistleblowers must formally identify themselves and include their full details in submissions, an approach that discourages those who fear for their safety.

Parliament subsequently passed an amendment (Law No. 182/2020) [5] that enables the competent Public Prosecution to receive disclosures. Through a ministerial decision, a Whistleblowers Reception Office was also created to facilitate disclosures, though this entity remains largely inactive and lacks public contact channels, such as a hotline or official website.

Another significant legislative milestone was crossed with the passage of Law No. 175/2020 on Combating Corruption in the Public Sector and Establishing the National Anti-Corruption Commission [6]. A central player in Lebanon’s anti-corruption architecture, the NACC was established as an independent commission endowed with legal personality, administrative autonomy, and financial independence—a status expressly affirmed by Article 5 of the Combatting Corruption law.

As specified by Article 18 of the Combatting Corruption law, the purview of the NACC's responsibilities encompasses:

• Gathering complaints pertaining to corruption, conducting thorough investigations into these complaints, and subsequently referring cases of corruption to the judiciary for prosecution.
• Monitoring the prevalence and economic implications of corruption, culminating in the publication of comprehensive reports on these matters.
• Providing expert insights and recommendations to combat corruption at both the international and local levels.
• Overseeing the creation and dissemination of educational materials, fostering awareness regarding the multifaceted efforts to combat corruption.
  

Moreover, the NACC is entrusted with executing specific functions as delineated in the Combatting Corruption law and supplementary legislation that pertains to anti-corruption endeavors. These functions include the acceptance of complaints relating to the non-implementation of the Access to Information Law and ensuring its effective execution. Additionally, the commission is responsible for receiving notifications from whistleblowers, ensuring their protection, and meticulously processing and auditing declarations of assets and interests.

Key Challenges

Absence of Enforcement Mechanisms

Although the NACC can issue decisions, such as ordering an agency to provide job protections, Lebanon’s legal framework omits explicit penalties for authorities that ignore or defy these directives. Without clear sanctions, violators face no meaningful consequences, and whistleblower protections risk becoming empty promises.

Dormant Whistleblowers Reception Office

Under the 2020 amendments, a Whistleblowers Reception Office was established to receive evidence of corruption and assist the Discriminatory Public Prosecution. However, no official website or hotline has been publicized, and no information is readily available to the public. This omission undermines the legislative intent of making the disclosure process more accessible and secure.

Coordination Gaps Between the NACC and Public Prosecution

Both the NACC and Public Prosecution may receive whistleblower disclosures, yet there is no codified mechanism to prevent redundant investigations or contradictory rulings. In complex, high-stakes corruption cases, parallel processes can cause confusion or even discourage informants unsure where to submit their evidence. A formal protocol to ensure consistent handling of disclosures is crucial.

Weak Deterrents Against Retaliation

Fines for offenses like breaching whistleblower confidentiality or workplace retaliation are nominal in Lebanese pounds. Ongoing currency depreciation has drastically reduced their deterrent effect, as these sums do not reflect the real cost of wrongdoing.

Unclear Physical Protection Measures

Legislation mentions “appropriate security measures” for whistleblowers but does not define such measures with specificity. Vague statutory language leaves security forces uncertain about resource allocation, while potential informants remain unaware of how or if effective physical protection will be provided.

No Anonymous Reporting

Requiring whistleblowers to disclose their full identity dissuades individuals concerned about backlash. The European Union’s Directive (EU) 2019/1937[7] explicitly encourages member states to allow anonymous reporting under certain conditions. Lebanon’s laws offer no such provision, leaving a critical gap for individuals with legitimate fears of reprisal.

Exclusion of NGOs and Media Outlets

Many international protocols and guidelines encourage multiple reporting channels. Civil society organizations (CSOs) and credible media outlets can serve as trusted conduits, especially when public confidence in governmental bodies is low. While Law No. 175/2020 recognizes the possibility of collaboration with such entities, the whistleblower protection framework itself does not explicitly authorize them to receive disclosures.

Recommendations

Allocate Adequate Funding and Enforce Compliance

Lebanon’s Parliament and Ministry of Finance must ensure sustainable budgetary support for the NACC. In the meantime, lawmakers should adopt provisions imposing penalties, fines, or criminal repercussions on any party refusing to implement NACC directives, especially those related to whistleblower protections.

Operationalize the Whistleblowers Reception Office

The Ministry of Justice should promptly launch a hotline and official website for the Reception Office, supplemented by secure data transmission protocols to protect whistleblower confidentiality. Public awareness campaigns can reinforce people’s trust in these channels.

Formalize Coordination Between the NACC and Public Prosecution

A memorandum of understanding is essential to prevent overlapping investigations and contradictory rulings. It should articulate streamlined case-handling protocols, designate primary and secondary contacts, and outline systematic information-sharing practices (e.g., centralized databases).

Recalibrate Fines to Reflect Current Realities

Legislators must adjust penalties to maintain their intended deterrent effect amid currency depreciation. One approach is to express fines in reference to an economic benchmark that is updated regularly, ensuring that punishments remain financially meaningful.

Define Physical Protection Measures

The Discriminatory Public Prosecution and internal security forces should establish clear procedures for evaluating threats and assigning resources to at-risk whistleblowers. This includes detailing what “security measures” entail—for instance, relocation assistance, protective escorts, emergency contact lines, and confidentiality protocols.

Allow Anonymous Disclosures

Amending Law No. 83/2018 to accept anonymous or pseudonymous reports subject to safeguards against malicious or unfounded allegations would align Lebanon’s policies with international standards. Such a measure would encourage disclosure by individuals who cannot safely reveal their identities.

Authorize NGOs and Media Outlets as Additional Channels

In line with international best practices, Lebanese law should explicitly permit disclosure to approved NGOs and reputable media organizations, provided they securely relay information to the NACC or Public Prosecution. This option fosters trust among whistleblowers who might be uneasy approaching state institutions directly.

Why is this important?

Lebanon’s whistleblower protection framework, rooted in Laws No. 83/2018 and No. 182/2020, seeks to uphold the rule of law by safeguarding citizens who expose corruption. Despite these legislative efforts, challenges remain from insufficient funding and coordination gaps to weak enforcement mechanisms and the inability to submit anonymous disclosures. Empowering the National Anti-Corruption Commission with adequate resources and ensuring it can effectively implement penalties are pivotal for restoring public trust and improving compliance.

Lebanon must solidify its whistleblower framework as a powerful deterrent against corruption. Doing so will signal to the international community, local reformers, and ordinary citizens alike that the country is committed to transparency and accountability, both indispensable elements of a functioning rule of law. In an environment where corruption has caused profound institutional damage and public despair, a robust whistleblower regime could serve as an essential component in Lebanon’s broader strategy for legal and economic reforms.

References

1. Law No. 83, dated 10/10/2018, Official Gazette No. 45 dated 10/18/2018, p. 4580
2. Transparency International. (2024). Corruption Perceptions Index 2024 – Lebanon.
3. International Monetary Fund. (2023). Staff Report for the 2023 Article IV Consultation with Lebanon. Washington, DC: IMF.
4. Law No. 33, dated 16/10/2008, authorizing the government to join the United Nations Convention Against Corruption approved by the General Assembly in its resolution No. 58/4 dated 31/10/2003, Official Gazette No. 44, dated 23/10/2008, p. 4389.
5. Law No. 182 dated 12/06/2020, Official Gazette No. 25 dated 12/06/2020.
6. Law No. 175, dated 8/5/2020, Combating Corruption in the Public Sector and Establishing the National Anti-Corruption Commission, Official Gazette, No. 20, dated 14/5/2020, p. 1203.
7. Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.