In the U.K., a whistle-blower has to show that they are not only reporting a crime, for example, but that it's in the public interest to report that crime.
In Ireland, rather than introduce a public interest test, we made it clear that only those disclosures not related directly to the employee's own contract of employment can be considered protected disclosures. That was aimed at preventing employees from mixing up personal grievances with public interest disclosures.