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How AI Companies Can Create a Safe Process for Raising Concerns

A safe AI concern-reporting process makes routes clear, protects reporters within stated limits, and connects reports to risk review and incident response.

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AI companies can make it safer to raise concerns by adapting a clear complaint or whistleblower process for AI-related issues, connecting reports to risk review and incident response, and explaining exactly what confidentiality and follow-up people can expect. The process should make it easy to find the right route without implying that every report is anonymous, legally protected, or within a regulator’s remit.

What a safe AI concern-reporting process needs to do

A reporting channel is useful only if concerns reach people who can assess and act on them. Build it into the company’s responsible-AI due diligence, risk management, and incident response rather than treating it as a standalone inbox.

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  • Make the route clear: explain how employees and other eligible people can submit concerns, what kinds of issues the channel covers, and what alternatives are available.
  • Make reports actionable: connect triage to appropriate risk assessment, investigation, incident response, and remediation.
  • Explain protections accurately: say whether anonymous reports are accepted, who can see identifying details, and what confidentiality and anti-retaliation policies apply. Do not promise protections beyond the company’s policies and applicable law.
  • Close the loop where possible: tell reporters what follow-up they can expect and how they can provide additional information.

The OECD Due Diligence Guidance for Responsible AI, published on 19 February 2026, recommends developing or adapting complaint and whistleblower procedures so staff can raise AI-related responsible-business-conduct concerns. It also recommends incident monitoring and response systems.

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How employees can safely report AI concerns at work

Companies should adapt existing complaint or whistleblower procedures where they work, while checking that the process complies with domestic regulations. A practical process should give a person enough information to choose a route and understand what may happen after they use it.

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  1. Identify the concern and route: state which AI-related concerns the internal channel handles and list appropriate alternatives, such as a manager, specialist internal function, independent channel, or regulator. Do not present internal reporting as the only option where law or circumstances allow external reporting.
  2. Make submission accessible: publish the channel, explain who is eligible to use it, and say what evidence or supporting material can be submitted. Consider language and accessibility needs.
  3. Set access and confidentiality rules: identify who reviews reports, who may access identifying information, whether anonymous submissions are accepted, and any limits on confidentiality.
  4. Describe triage and escalation: explain how reports are assessed and when they may be referred into risk review, incident response, or remediation.
  5. Explain follow-up and retaliation safeguards: say whether reporters can receive updates or submit more information, and describe the anti-retaliation measures the company actually maintains.

The OECD guidance also calls for broad decision-making and stakeholder engagement, including workers, worker representatives, and trade unions. Involving these groups when designing or reviewing the process can help ensure that it is usable and that affected perspectives reach the relevant decision-makers.

How to connect reports to AI risk management

Use the company’s risk-management process to decide what a report needs next: assessment, investigation, incident response, corrective action, or another form of remediation. A concern can identify a potential risk before an incident occurs, so the process should not require reporters to prove that harm has already happened.

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NIST’s AI Risk Management Framework offers a voluntary, broader structure for AI risk work through four functions: Govern, Map, Measure, and Manage. The NIST AI RMF Playbook provides related guidance. These materials can help frame governance and risk review, but they do not prescribe a particular employee reporting channel. NIST says the framework is being revised, so check its current status when using it.

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For each reporting route, define how its reports enter the company’s existing review and response processes. A report that indicates a serious incident may also trigger legal or regulatory duties; those duties are distinct from the internal process for receiving and assessing concerns.

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Internal reports, EU complaints, and serious-incident notifications are different

People should not have to guess whether an internal report, an external complaint, or a legally required notification is the right route. These mechanisms differ in purpose, eligibility, and scope.

Route Who it is for and what it covers What to keep in mind
Company complaint or whistleblower process People eligible under the company’s policy; AI-related responsible-business-conduct concerns within the stated scope. The company defines its process subject to applicable law. State its actual rules for anonymity, confidentiality, review, and follow-up.
EU AI Act Whistleblower Tool People professionally connected to providers of general-purpose AI models or certain AI systems within the AI Office’s enforcement remit. This is a specific external channel, not a universal route for every AI concern. Check current eligibility and remit.
EU AI systems Complaints Tool Complaints about alleged infringements involving AI systems within the AI Office’s exclusive competence. Other AI systems may fall to national competent authorities; not every complaint is within the AI Office’s remit.
AI Act Article 73 serious-incident reporting Provider reporting obligations for specified serious incidents involving high-risk AI systems. This is a separate legal obligation with requirements tied to incident type, investigation, risk assessment, corrective action, and cooperation.

The European Commission’s AI Act Whistleblower Tool says that submissions can be anonymous, made in any EU language, and accompanied by supporting documents. Its secure inbox allows follow-up while preserving anonymity, and the Commission says it has documented internal procedures to protect whistleblowers’ identities. These are features of that Commission tool, not guarantees that apply to company channels generally.

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The AI Act Service Desk distinguishes that whistleblower route from the AI systems Complaints Tool. The Service Desk’s page for Article 73: Reporting of serious incidents describes a separate provider obligation. Its displayed text is based on the consolidated AI Act as at 27 July 2026. Applicability and deadlines depend on the law and circumstances; verify the current text rather than treating an employee concern as a substitute for a required notification.

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How to compare reporting routes

If a company offers more than one channel, compare them on the information a person needs to choose safely and on how the company handles what comes in:

  • Who may use the route, and which concerns it covers.
  • Whether it is internal or external, and how independent its reviewers are.
  • Whether anonymous reports are accepted, who can identify a reporter, and the limits of confidentiality.
  • Available languages and accessibility options.
  • Whether a person can provide evidence and continue a conversation securely.
  • How a report reaches risk assessment, incident response, and remediation.
  • Which legal duties and geographic limits apply.

The EU AI Office tool is one published example with specific eligibility, language, anonymity, document-submission, and follow-up features. It is not evidence of a universal best internal process; companies need to define a route that fits their work and applicable requirements.

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