Whistleblowing channel deadlines

Receipt communication

Portuguese Law No. 93/2021 provides that the whistleblower should be notified of receipt within seven days, except in the situations provided for by the law.

Information on measures

The whistleblower should receive substantiated information on measures planned or taken within a maximum of three months from receipt.

Request for information on the outcome of the assessment

The law also provides that the whistleblower may request communication of the outcome of the assessment after it has been completed.

Operational organisation

Assign responsible people, record dates, set internal alerts and maintain a history of communications and decisions.

Seven days: acknowledgement of receipt

Acknowledgement of receipt should be part of a controlled process and not depend solely on a manual reply. The organisation should define who checks new reports, how absences and public holidays are handled and what information is communicated without compromising confidentiality or the investigation.

Three months: information on measures

The deadline for providing information on measures planned or taken requires earlier internal milestones. Triage, assignment, requests for clarification, assessment and decision-making should have their own responsible people and dates, enabling a substantiated communication within the applicable deadline.

Internal operational milestones

In addition to legal deadlines, internal targets can be set for initial review, assignment, contact, assessment and closure. These targets do not replace the law but help identify bottlenecks, manage priorities and demonstrate consistent channel follow-up.

Deadline control map

Legal deadlines should be supported by shorter operational milestones. Recording the receipt date, assigning substitutes and using escalation alerts reduce the risk of a report being left without follow-up during absences or periods of high volume.

A control map should include at least:

• Date and time of receipt, using a consistent time reference.
• Acknowledgement to the reporter within the applicable seven-day period.
• Date of first assessment, assigned owner and any clarification requests.
• Internal milestones for triage, investigation, review and decision.
• Reasoned information on planned or adopted measures by the three-month limit.
• Record of any outcome request and the response after conclusion, where applicable.
• Alerts, substitution and escalation before each critical deadline.
• Retention of the record for at least five years and while related proceedings remain pending.