I don't believe that is all that clear.
The Justice Department has wide latitude to interpret the requirements of such laws and told the DNI that the whistleblower law didn't apply here. The DNI is bound to follow their advice.
Whether Justice came to the right conclusion may be debatable, but there's an argument that the whistleblower law was for finding issues in the intelligence community and the president isn't part of that community. There's an argument to be had there.
The Justice Department is run by Bill Barr, who Trump mentions by name in the "Transcript" as someone Trump will tell to call the Ukrainian government to "get to the bottom" of the Biden allegations.
Did Barr know about the DoJ going through the process to make that determination? Did he recuse himself from the discussion? Barr might argue that the DoJ decision was correct, but he should not have been the one making that decision in the first place.
You're a strong and powerful ally, I'll do what I can...