What is substantive feedback under Article 9(1)(f)?

Article 9(1)(f) of EU Directive 2019/1937 requires the channel operator to provide feedback to the reporter within three months of acknowledgement (or expiry of the 7-day rule) on the actions envisaged or taken, and the grounds. It is not the full findings report; it is a substantive summary that lets the reporter understand what has happened with their report.

What if the investigation is not yet complete?

The Directive expects feedback even for ongoing investigations. The feedback in that case states that the investigation is ongoing, what stage it is at, what has been done so far, and when next feedback will be provided. The three-month deadline cannot be deferred by 'no result yet'.

What if the deadline must be extended?

Most national transpositions allow extension to six months in cases of particular complexity, with notice to the reporter before the original deadline. The extension is not automatic; it requires a written reason and a defined further deadline. Confidly's case timeline tracks both deadlines and flags the extension event.

Free template · Updated May 2026

3-Month Substantive Feedback Message

Four variants of the substantive feedback message required within 3 months under Article 9(1)(f) of EU Directive 2019/1937: substantiated outcome, partially substantiated, unsubstantiated, and ongoing investigation (with extension).

Variant A: Substantiated

Dear reporter,

I am writing further to your report submitted on [date] under case code WB-XXXX-YYYY, and the acknowledgement I sent on [date].

The investigation is now complete. Based on the evidence collected, the allegation that [neutral paraphrase] is substantiated. The following remedial actions have been taken or are now being taken:

[HR action, in general terms, e.g., disciplinary process initiated against the responsible person; final outcome will be communicated to the affected parties through the usual channels].

[Policy update, training, or system control adopted, in concrete terms].

[External notification or referral, where applicable].

I cannot disclose individual personnel decisions or privileged investigation material; the description above is the level of detail I am able to share with you. The audit log of the case is available to regulators on request.

Thank you again for raising this. Your report led directly to the actions above. You are protected from retaliation under [article reference]; if you experience any adverse consequences, contact me immediately.

If you have further information or wish to discuss, message me through the channel.

[Name], [Role]

Variant B: Partially substantiated

Dear reporter,

The investigation into your report (WB-XXXX-YYYY) is complete. Some elements of the allegation are substantiated; others are not.

Substantiated: [neutral paraphrase of the substantiated element]. The remedial actions taken in response:

[Action 1].

[Action 2].

Not substantiated: [neutral paraphrase of the unsubstantiated element]. The evidence reviewed does not support a finding on the balance of probabilities. This conclusion does not reflect on your good faith in raising the concern; partial outcomes are common in investigations.

Your anti-retaliation protection continues. If circumstances change, you have the option of returning to the channel with new information, or escalating to the national authority at [URL].

[Name], [Role]

Variant C: Unsubstantiated

Dear reporter,

I have completed the investigation into your report (WB-XXXX-YYYY). On the evidence available, the allegation that [neutral paraphrase] could not be substantiated. This conclusion is on the balance of probabilities and reflects the evidence we were able to collect within the available scope.

The investigation included [list, in general terms: documentary review, interviews with witnesses, expert input], conducted over [n] weeks. Specific findings and evidence are documented in the case file. The closure recommendation was reviewed and approved by the closure panel ([roles, not names]).

An unsubstantiated outcome does not mean the report was unfounded or that you acted in bad faith. The Directive's protections apply equally to reports that turn out to be unsubstantiated, provided you had reasonable grounds to believe the information was true.

Your anti-retaliation protection continues for as long as the protection regime applies. If you experience adverse consequences linked to having raised this concern, contact me immediately.

If new information becomes available, you can submit a fresh report. You also have the option, at any time, of escalating to the national authority at [URL].

Thank you for engaging the channel.

[Name], [Role]

Variant D: Ongoing investigation, with extension

Dear reporter,

I am writing on the 3-month deadline for substantive feedback on your report (WB-XXXX-YYYY). The investigation is ongoing.

Progress to date: [in general terms, e.g., documentary preservation completed on [date]; [n] witness interviews conducted; expert input requested on [date] and expected by [date]].

Because of the complexity of the matter, I am extending the feedback deadline by a further three months, as permitted under [article reference]. I will provide the next substantive feedback no later than [new date]. If meaningful developments occur earlier, I will update you sooner.

Your anti-retaliation protection continues. The case file and audit log are complete to date and remain available to the relevant decision-makers.

If you have further information or questions, message me through the channel.

[Name], [Role]

Voice and tone notes

Plain language; avoid legalese.
Direct and factual; no euphemisms about adverse outcomes.
Acknowledge the reporter's role in initiating the case without putting them in the position of being thanked for a hardship.
Do not disclose other reporters, other cases, the identity of the subject, or privileged investigation material.
Always close with the anti-retaliation reminder and a route for escalation.