The year 2025 marks the end of whistleblowing as a mere formality: three rulings—by the Court of Milan, the Court of Bergamo, and the Court of Cassation—have transformed Legislative Decree 24/2023 into a substantive tool for rebalancing workplace relationships.

With Judgment No. 1680/2025, the Court of Milan applied the relative presumption of retaliation for the first time: when dismissal follows the report in time, the burden of proof shifts, and it is up to the employer to demonstrate that the termination is entirely unrelated to the report. The Court of Bergamo, in judgment no. 951/2025, awarded presumed moral damages (€25,000) to a whistleblower exposed to a hostile environment, without requiring forensic medical evaluations, thereby recognizing the existential impact of isolation.

Finally, the Court of Cassation, in judgment no. 1880/2025, reaffirmed the objective limit of protection: the prohibition on retaliatory measures does not apply when the report is used for essentially personal purposes or for claims related solely to the employment relationship. A typical example is the case of an employee who, facing dismissal for poor performance or a legitimate transfer, files a “report” based solely on internal conflicts to effectively make themselves untouchable. If the content concerns only interpersonal dynamics or unwelcome management decisions, without reporting illegal acts provided for by law or violations of the 231 Model, whistleblower protection does not apply: the objective prerequisite of defending legality is lacking.