ASIC’s whistleblower benchmarking shows a simple pattern, access plus follow-through drives reporting

Between July 2024 and June 2025, 134 Australian companies told ASIC how their whistleblower programs actually worked in practice, not just what their policies said. Together they reported 8,095 disclosures, but the spread was wide, and that spread is the point.

One way to read the report is as a maturity map. Another way is as a set of prompts for boards, HR, legal, compliance, and risk leaders to ask, “If our numbers look ‘quiet’, what could that mean here?”

The uncomfortable headline, many companies hear nothing

ASIC found the median disclosure rate was 0.22 disclosures per 100 employees, and 22% of surveyed companies reported zero disclosures for the year.

Zero can be “good”, but it can also be “quiet”. Those two look identical on a dashboard.

In some organisations, issues are handled early through direct managers, HR, union channels, or safety reps, so whistleblowing channels stay quiet.

In others, people have learned that speaking up creates effort without outcomes, or worse, personal downside. Silence becomes a rational choice.

In some cases, reporting exists, but classification is messy. Things are logged as grievances, complaints, or ethical queries, so the whistleblower program looks inactive even when employee concerns are active.

What this means for leaders is simple. Low numbers are not proof of trust. They are a signal that needs context, like workforce mix, front-line versus corporate roles, contractor ratios, and regulatory exposure.

What people report is often about work, not just fraud

A large share of disclosures were not classic “fraud hotline” topics. Companies said that about 39% of disclosures were in-scope for whistleblower protections under the Corporations Act. For around 68% of companies, the most commonly reported wrongdoing was workplace mistreatment, disputes, or grievances.

That mix creates a design challenge:

If your whistleblower channel becomes a catch-all grievances inbox, investigators get swamped and serious matters may slow down or worse be missed.

If your channel feels “only for financial crime,” people may not use it even when something serious is happening.

The leadership move here is to design for reality. Effective programs often have clear triage, clear language, and clear routing. They protect the discloser early, then move the matter to the right lane without making the person feel dismissed.

Reading “quiet” numbers with more care

ASIC’s benchmarking is not telling organisations to chase “higher numbers.” It is showing that silence is ambiguous. The more practical question is whether your program makes it easy to speak up, and credible to follow through when someone does.

Speak with our consultants

If you would like an outside view on how your current program compares, speak with our consultants for a complimentary consultation.

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