A whistleblower disclosure must concern misconduct or an improper state of affairs or circumstances within an organisation.
The whistleblower must have reasonable grounds to suspect the information shows wrongdoing — they do not need to prove it at the time of reporting.
Examples of issues that may qualify include suspected:
- breaches of financial services, credit, corporations or superannuation laws administered by ASIC or APRA
- fraud, theft, corruption, market manipulation, or dishonesty
- misleading or deceptive conduct affecting clients or markets
- serious failures in governance, risk management or compliance
- conduct that represents a danger to the public or the financial system
- other serious Commonwealth offences punishable by 12 months’ imprisonment or more. ASIC+2ASIC+2
What doesn’t normally qualify?
A disclosure solely about a personal workplace grievance (such as an individual dispute over pay, promotion, performance, or interpersonal conflict) is usually not protected under the whistleblower regime unless it also reveals broader misconduct or systemic issues.
For licensees and advisers, a useful rule of thumb is if the concern goes beyond one person’s employment issue and points to legal/regulatory breaches, systemic conduct, client harm, or governance failures, it may be a qualifying whistleblower disclosure.