As MortMan posted in 33 above, there was a first-hand standard for the ICIG to forward the complaint to Congress but not for the WB to make the complaint, which is the part governed by statute.
Once again, it's moot because the IG determined that the WB did have direct knowledge.
It's all in the ICIG statement you just linked.
RE: the IG determined that the WB did have direct knowledge.
OK, let’s say that I agreed with everything you just said ( which I don’t yet ).
The issue then becomes the “Direct Knowledge” that the ICIC claimed the WB has.
We already have the transcripts of the exchange with Zelensky. It showed NO QUID-PRO-QUO. Nothing impeachable as I read it. If that is NOT what the ICIG is referring to, what “Direct Knowledge” other then the one in the transcript does this Whistleblower have and why is that other knowledge ( if it exists ) not being made public?
Furthermore, The embattled ICIG also admitted last Friday that the anti-Trump complainant lied on his whistleblower complaint form by concealing the complainants previous secret interactions with House Democratic staff prior to submitting the complaint.
Atkinson never even bothered investigating potential coordination between the complainant, whom DOJ said showed evidence of partisan political bias, and House Democrats prior to the filing of the anti-Trump complaint.