Writing Art. 5(13)-compliant feedback

Feedback is a deliberate decision, not a byproduct of activity

Whatever channel you're running, feedback in the Directive's sense is something a handler has to deliberately decide has happened — it's never a natural side effect of a case having activity on it. Provoxis makes that explicit with its own status model: FeedbackGiven is one of four case stages (New → Investigating → FeedbackGiven → Closed), reached only when a handler sets it directly, never automatically. But the underlying discipline holds regardless of what system, or lack of one, you're using: it's easy to assume feedback has effectively happened just because there's been back-and-forth with the reporter. It hasn't, until someone actually decides it has and can point to the moment that happened.

What actually counts as feedback

The bar is the Directive's own Art. 5(13) definition: "information on the action envisaged or taken as follow-up, and the reasons for it." Two things, both required, on any channel:

• What's being done — the actual action, whether that's disciplinary steps, a policy change, a referral elsewhere, or a decision that no further action is warranted.
• Why — the reasoning behind that action, not just the fact of it.

A message that only does one of those isn't feedback in this sense. Telling a reporter "we looked into it" states an action happened without saying what it was. Telling them "we're taking this seriously" is reassurance, not information. Both fall short of what Art. 5(13) actually requires, even though they might feel like adequate communication in the moment.

What does satisfy it, in plain terms: "We investigated and found the allegation substantiated; the person involved has received a formal warning and the team's expense-approval process has been changed to require a second sign-off" is feedback. So is "We investigated and found no evidence to substantiate the allegation, so no further action is being taken" — a negative outcome, clearly stated with its reasoning, is still feedback. What isn't feedback is silence, a vague reassurance, or an ordinary clarifying-question exchange that never actually states an outcome.

Ordinary messages don't count, and closing a case doesn't either

Two things that feel like progress but don't discharge the obligation on their own, whatever system tracks them:

• Back-and-forth messaging. Answering a reporter's question, or asking them for more detail, keeps the conversation moving but isn't feedback unless one of those messages actually states the action taken and why.
• Closing the case. On many systems, including Provoxis, a case can move straight to Closed without ever passing through a feedback stage — the workflow allows that step to be skipped. If it is, the feedback obligation stays unmet. Closing a case archives it; it isn't itself evidence that the reporter was told anything.

If new information comes in after feedback's already been given

Whatever system you're on, you need some way to get a case back into active investigation if something material comes to light after feedback was already given — appending an update onto a case that's already been marked resolved isn't the same as genuinely reopening it. In Provoxis, FeedbackGiven and Closed are the only two statuses that can move backward, and only to Investigating; every other backward move is disallowed, which is what makes reopening a deliberate, visible step rather than something that happens quietly.

Legal basis

• Art. 5(13), Directive (EU) 2019/1937 — the definition of "feedback" this obligation is built around.