WOLFSBURG, Germany — Nearly three years after Volkswagen admitted to a vast emissions cheating scheme, the company has only just begun to take steps necessary to prevent future scandals.

That was the main takeaway from a report issued Monday by a prominent American lawyer appointed to monitor the company’s behavior. Among other things, Volkswagen still has work to do to create an adequate whistle-blower program, the lawyer, Larry D. Thompson, wrote in the report.

In interviews before the report was issued Monday, Mr. Thompson said it was intended not as a criticism of the company but rather as recommendations for future action.

“My mandate is a forward-looking one,” he said in Wolfsburg, Volkswagen’s base.

Still, the implication was that Volkswagen has made insufficient progress toward repairing the shortcomings in company culture and internal controls that led to one of the biggest corporate scandals ever.