Wet zorgplicht kinderarbeid (Child Labour Due Diligence Act), Stb. 2019, 401

Directive requiring very large EU and non-EU companies to identify, prevent and address adverse human rights and environmental impacts in their own operations, their subsidiaries' operations and their chains of activities. Omnibus I (Directive (EU) 2026/470) raised the thresholds, deleted the climate transition plan obligation, removed the EU-wide civil liability rule (liability now rests on national law), and capped fines at 3% of net worldwide turnover.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2028. National measures apply to all in-scope companies from 26 July 2029; Article 16 reporting applies for financial years starting on or after 1 January 2030.

Covered entities

EU companies with more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover, or ultimate parents of groups reaching those thresholds. Non-EU companies with more than EUR 1.5 billion net turnover in the EU in the financial year before the last. Separate thresholds apply to franchising and licensing groups (royalties above EUR 75 million plus turnover above EUR 275 million).

Companies in scope must identify, prevent, and remediate human rights and environmental risks in their own operations and direct suppliers, with risk-based duties extending to indirect suppliers when substantiated knowledge arises. BAFA monitors compliance, can issue orders, and impose fines up to EUR 8 million or 2 percent of average annual turnover (where turnover exceeds EUR 400 million).

Enforcement

Mandatory

Effective date

1 January 2023 (companies with 3,000+ employees in Germany); 1 January 2024 (1,000+ employees in Germany)

Covered entities

Companies with their head office, principal place of business, administrative seat, or registered branch in Germany and at least 1,000 employees in Germany (3,000+ in 2023). Includes German branches of foreign companies.

Covered enterprises must conduct human rights and decent working conditions due diligence aligned with the OECD Guidelines, publish an annual account of their efforts by 30 June, and respond in writing within three weeks to public information requests. The Consumer Authority supervises through guidance, decisions, and enforcement penalties.

Enforcement

Mandatory

Effective date

1 July 2022; first annual due diligence accounts due by 30 June 2023

Covered entities

Larger Norwegian enterprises and foreign enterprises selling goods or services in Norway that are tax-liable in Norway. Companies must meet two of three thresholds: NOK 70 million sales revenue, NOK 35 million balance sheet total, 50 FTE employees.

In-scope parent and ordering companies must establish, publish, and effectively implement a vigilance plan covering risk mapping, supplier and subcontractor assessment, mitigation actions, an alert mechanism, and a monitoring scheme addressing human rights, health and safety, and environmental harm across the group and established business relationships. Any party with standing can give formal notice and, after three months of non-compliance, seek a court injunction and damages.

Enforcement

Mandatory

Effective date

27 March 2017; first vigilance plans required for FY2017

Covered entities

French-headquartered companies that, for two consecutive years, employ at least 5,000 employees in France (parent and direct/indirect subsidiaries) or at least 10,000 employees worldwide.

In-scope Swiss companies must operate a supply chain management system, traceability and risk management aligned with the OECD Due Diligence Guidance for minerals and the ILO-IOE child labour due diligence guidance, and publish an annual report. False or missing reports can trigger fines up to CHF 100,000 under Art. 325ter of the Swiss Criminal Code.

Enforcement

Mandatory

Effective date

1 January 2022; one-year transition meant first reporting period was FY2023

Covered entities

Companies with registered office, head office, or principal place of business in Switzerland that import or process tin, tantalum, tungsten, gold (3TG) above annual volume thresholds set in the DDTrO annex, and companies that offer products or services where there is reasonable suspicion of child labour. SMEs and low-risk companies are exempt under defined conditions.

Covered organisations must publish an annual modern slavery and human trafficking statement, approved by the board (or equivalent) and signed by a director, setting out the steps taken (or stating that no steps were taken) to ensure slavery and human trafficking are not occurring in their business or supply chains. The Home Office maintains a central registry and the Secretary of State may seek civil injunctions for non-compliance.

Enforcement

Mandatory

Effective date

29 October 2015; first statements required for financial years ending on or after 31 March 2016

Covered entities

Commercial organisations (any body corporate or partnership, wherever incorporated) carrying on any part of a business in the UK and supplying goods or services with a total annual turnover of GBP 36 million or more (group turnover where applicable).