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Hinweisgeberschutz

Status Notification

The mandatory feedback that organisations must provide to a whistleblower within three months of acknowledging their report, informing them of any follow-up measures taken.

A status notification (Sachstandsmitteilung) is the statutory follow-up communication that the responsible person managing an internal reporting channel must send to the whistleblower within three months of acknowledging receipt of the report. Under § 17 of the German Whistleblower Protection Act (HinSchG), the notification must inform the reporter about the measures that have been taken or are planned in response to their report, to the extent permitted by law and the legitimate interests of the persons concerned.

The status notification is an important element of the reporter's procedural rights. It ensures that whistleblowers are not left in the dark about the outcome of their report and provides transparency about how the organisation handles compliance matters. The notification need not disclose confidential details of the investigation or the identities of persons involved, but it must provide a meaningful update rather than a generic acknowledgement.

In practice, a status notification might state that the report has been reviewed and found to be outside scope, that an internal investigation has been launched, that the matter has been referred to an external authority, or that the investigation has been concluded and corrective measures have been implemented. Organisations should document all status notifications carefully to demonstrate compliance with the HinSchG's procedural requirements.

Legal Basis

§ 17 Hinweisgeberschutzgesetz (HinSchG); Art. 11 EU Directive 2019/1937

Practical Example

An employee reports a suspected breach of data protection rules through the company's whistleblower system on 1 March. The compliance officer acknowledges receipt on 5 March (within the seven-day deadline). By 5 June – three months later – the compliance officer sends a status notification through the secure case management platform, informing the reporter that an internal investigation confirmed the breach, that the relevant process has been corrected, and that the data protection officer has been notified. The reporter is satisfied and the organisation has met its statutory obligations.

FAQ

The status notification must inform the reporter about the follow-up measures taken or planned in response to their report. It may include information about whether an investigation was launched, whether the matter was referred to an authority, or what corrective actions have been implemented. Confidential details about the investigation or third parties need not be disclosed.
The status notification must be provided within three months of the date on which receipt of the report was acknowledged. If no acknowledgement was sent, the three-month period runs from the end of the seven-day acknowledgement deadline.
For anonymous reporters, the status notification should be delivered through the same secure channel used for the original report, such as the anonymous two-way messaging function of the whistleblower platform, using the case ID known only to the reporter.

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