Impunity 82. It is crucial that perpetrators of torture face accountability for their actions. Impunity for perpetrators acts as an incentive for public officials to acquiescence in or commit other acts of torture or other ill-treatment, and masks the true scale of the problem, disincentivizing authorities from taking effective measures to prevent and eradicate torture and other ill-treatment in their respective jurisdictions. Impunity and the related low rate of criminal investigations and convictions for acts of torture remains a key concern throughout the OSCE region. Of the countries surveyed, CSOs in eight OSCE participating States all cited impunity as a key reason for the continued use of torture.179 There are numerous and intertwining reasons why states fail to hold perpetrators of torture accountable, but the lack of effective mechanisms, including complaint and reporting mechanisms and the legal framework needed to investigate, prosecute and punish torture, is a significant area of concern. Reporting torture 83. In order for an investigation into torture or other ill-treatment to be conducted, an allegation of torture has to be made or the suspicion of torture has to be raised. Allegations of torture or other ill-treatment must be dealt with immediately and must result in a prompt and impartial investigation conducted by an independent authority.180 In the majority of cases, the onus will be on the victim to raise an allegation of torture or to make a formal complaint. In some countries, victims of torture may face prosecution for a “false denunciation” of torture if their complaint of torture fails to result in the conviction of the alleged perpetrator.181 Given the low rate of convictions for torture, this discourages many victims from even lodging complaints in the first place.182 A report about one OSCE participating State in Central Asia noted that among victims of torture “[t]hose who do lodge complaints 179 Questionnaire responses from Armenia, Kyrgyzstan, Moldova, North Macedonia, Russia, Serbia, Tajikistan, and Ukraine (2019). 180 See e.g. Nelson Mandela Rule 57(3) in relation to prison settings. 181 OSCE Human Dimension Implementation Meeting, Torture and ill-treatment in Central Asia (Working Session 5, Rule of Law II, 12 September 2018), page 2. 182 Ibid. 53