From what moment does the three-month deadline begin to run?
The three-month deadline for providing feedback to a reporter does not begin on the day the report is received. It begins at the moment of the acknowledgement of receipt, or, if that acknowledgement has not been sent, after the expiry of the seven-day deadline that applies to it. In other words: the starting point is linked to the first statutory step, not to the report itself.
This distinction may seem small, but it has consequences in practice. If the acknowledgement of receipt is sent on day six, the three-month clock also starts running on day six. If no acknowledgement is sent at all, you must yourself reconstruct when the seven-day deadline has expired — and that is precisely where things go wrong, because that date is not documented anywhere.
Why this starting point causes confusion
Many handlers unconsciously assume that the clock starts on the day the report is received. That is incorrect, and the difference of a few days seems unimportant until the deadline approaches. For a report received on 1 March and whose acknowledgement of receipt is sent only on 6 March, the final date for providing feedback is therefore five days later than if you had started counting from 1 March. When you have multiple cases running at the same time, that difference is precisely the kind of detail you would rather not track manually.
Another source of confusion is the question of what exactly must happen within those three months. Providing feedback does not mean that the investigation is complete and the matter is resolved. It means that the reporter is informed about the envisaged or taken follow-up steps. For a straightforward report, that may be a concrete outcome; for a more complex matter, it may also be an interim update, as long as the reporter hears something within the deadline.
If no acknowledgement of receipt has been sent
The situation in which no acknowledgement of receipt has been sent occurs more often than expected — particularly for oral reports that have not been immediately documented, or for reports that reach the correct person through a roundabout route. In that case, the three-month deadline runs from the moment when the seven days for the acknowledgement have expired, even if nothing has been sent. The clock does not stop because the first step was missed; it simply continues based on the date on which the report was made.
This is precisely why documenting the date of receipt from the first moment is important. Without a documented starting point, you must reconstruct after the fact when a report was received, and that is error-prone, especially if the report was made orally or passed on through several people before it reaches the handler.
Where the timeline breaks down in practice
In practice, there are a few recurring reasons why the three-month deadline comes under pressure. The first is absence: a handler who goes on holiday or becomes ill, while the deadline continues to run. The second is complexity: an investigation that requires more time than planned, without interim feedback being provided to the reporter. The third is an unclear starting point: nobody who knows exactly what date the report was received, because this has not been systematically documented anywhere.
None of these reasons is exceptional, and none of them requires a complicated solution. What does help is an environment in which the date of receipt, the acknowledgement of receipt and the final date for providing feedback are automatically tracked, so that you do not have to make a calendar item of it yourself. Signalo does this in the background: the two deadlines run automatically as soon as a report is received, regardless of who received the report or how it was made.
It is up to you and, where necessary, to a legal adviser to assess how you handle any delays or complexity within that three-month period in a specific case. Signalo monitors the deadline and structures the process, but does not assess the report itself and provides no legal advice on the content of a matter.
Learn more about the rest of the process
The three-month deadline does not stand alone; it is linked to the acknowledgement of receipt, the way a report is recorded and the way you close a case. In the knowledge base with explanations for each step you will find the other elements of the process, separate from your specific situation. If you first want to know whether the reporting obligation applies to your organisation, then the questionnaire with an indication provides clarity on that in a few minutes.
If you want to see how the deadlines are technically monitored and where that information comes from, you can read that on the page on how the platform works. If you want to start directly with an environment in which the deadlines run automatically, you can do so via setting up a business account.
Feel free to first do the free quick scan to see whether the reporting obligation applies to your organisation, or browse through the knowledge base for the other steps in the process.