In this paper I will examine the ongoing debate on what are the reasons behind opposition to the introduction of financial rewards to whistleblowers in most European jurisdictions. I will approach this debate from two main angles. First is that of the mainstream corruption studies approach with its two main prongs: the collective action and the principal agent theories. I find that the principal – agent theories in general are supportive towards the introduction of the financial rewards as they see them as another tool that would incentivize accountability of the different agents that operate within a given field. The collective action theories would also be supportive but with a caution stemming from the different possible contexts within which the financial rewards are introduced.
The second angle of the paper is that of the comparative legal traditions, those of the US and the European law. Following their different trajectories, I map the introduction of whistleblower protection within the different jurisdiction seeking to understand the deeper societal forces and their legal expressions which oppose the introduction of financial rewards. I find that the existing tension between principal – agent and the collective action theories in a way is mirrored in the tension and the different lenses that the US and European continental law have. Putting this into perspective of wider solutions from the anti-corruption toolbox, I find the eventual introduction of the financial rewards likely but with questionable efficiency.
