Feedback
Feedback is the information that must be given to the reporting person within three months of the acknowledgement of receipt about the follow-up measures planned or already taken and the reasons for them.
Feedback is a core obligation of both internal and external reporting channels towards the reporting person. It requires the reporting channel to inform the reporting person, within three months of the acknowledgement of receipt, which follow-up measures are planned or have already been taken and on what grounds. Feedback therefore differs both from the acknowledgement of receipt, which must be sent within seven days, and from the mere handling of the report: it creates transparency about the status and outcome of the procedure and strengthens the reporting person's trust in the effectiveness of the whistleblowing system.
Feedback typically covers follow-up measures within the meaning of the law, such as internal investigations, contacting affected persons and units, referring the case to a competent authority, closing the procedure for lack of evidence, or transferring it to another body. The content of the feedback must be framed so that internal enquiries or investigations are not impaired and the rights of persons concerned by a report remain unaffected. In doing so, the reporting channel upholds the confidentiality requirement and discloses only the information that may be shared without endangering the procedure and without harming the legitimate interests of third parties.
Feedback must be distinguished from a status update, which can serve as interim information in procedures of longer duration, and from the acknowledgement of receipt as the first formal step. If the three-month deadline is missed or no proper feedback is provided, the reporting person may be entitled to turn to an external reporting channel or, under the statutory conditions, to make a public disclosure without losing their protected status. Careful, timely and documented feedback is therefore not only a legal duty but also a precondition for a legally sound and credible whistleblowing system.
Legal Basis
Section 17(2), Section 28 HinSchG (German Whistleblower Protection Act); Art. 9(1)(f), Art. 11(2)(d) EU Whistleblowing Directive (Directive (EU) 2019/1937)
Practical Example
At a mid-sized company, the internal reporting channel receives a tip about possible corruption in procurement. The compliance officer sends the acknowledgement of receipt within seven days and opens an internal investigation. Because reviewing the supplier contracts takes time, she sends a status update after six weeks. Just under three months after the acknowledgement of receipt, she provides feedback: she informs the reporting person that the investigation has partly confirmed the suspicion, that one supplier has been terminated and that the internal four-eyes principle in procurement has been tightened. She does not name specific personal details of the employees concerned, in order not to jeopardise the presumption of innocence and the ongoing employment-law review. She documents the feedback in an audit-proof manner in the case management system.