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NO-TransparencyIn force from 1 July 2022

Åpenhetsloven (Lov om virksomheters åpenhet og arbeid med grunnleggende menneskerettigheter og anstendige arbeidsforhold), LOV-2021-06-18-99

Norway · Forbrukertilsynet (Norwegian Consumer Authority)

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.

Category
Mandatory due diligence
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.
Notes
Supervisory body provides guidance and can impose binding decisions and infringement fines. Reports must be signed by the board. Act last amended by Law 2024-06-21-42 (in force 1 November 2024). Pending (not adopted): the Ministry of Children and Families has consulted on removing the remaining 'negotiation model' in the Marketing Control Act and the Transparency Act, so the Consumer Authority can issue decisions and sanctions without first negotiating, and on a regulation allowing enterprises to refuse information requests about exports of goods, technology and services subject to export controls. Consultation deadline reported as 30 September 2026.

Sources

Related regulations

In force; revised packaging EPR rules applied from 1 July 2025; EPR for certain single-use plastic products (Chapter 7A) added in November 2025 and for plastic-containing fishing and aquaculture gear (Chapter 7B) from 1 January 2026. A new packaging regulation implementing the EU PPWR has been proposed to the ministry but is not yet out for consultation.

Norway implements EU-style EPR through Avfallsforskriften, requiring producers of packaging, EEE, batteries and vehicles to join a producer responsibility organization approved by the Environment Agency. Since July 2025 the previous 1,000 kg-per-material exemption for packaging has been abolished, so every importer or producer must register and report. Chapter 7A requires producers of certain single-use plastic products to join an approved scheme and cover municipal cleanup and collection costs from 2027, and Chapter 7B sets EPR for plastic-containing fishing and aquaculture gear.

Enforcement
Mandatory
Effective date
Avfallsforskriften in force since 2004 (latest amendment FOR-2025-12-18-2839, in force 1 January 2026); Chapter 7 packaging EPR revised effective 1 July 2025 (lower registration limit removed); Chapter 7A in force on adoption (FOR-2025-11-12-2278), with the duty to cover municipal costs applying to costs from 1 January 2027 and first payment due 1 October 2028; Chapter 7B in force 1 January 2026, with §§ 7B-4 to 7B-7 applying from 1 March 2027; WEEE provisions since 1999
Covered entities
Any company that professionally imports or manufactures packaging, packaged products, EEE, batteries or vehicles for the Norwegian market; from July 2025 all packaging producers regardless of volume. Also producers that first place certain single-use plastic products on the Norwegian market (food and beverage containers, cups, flexible food packaging, light carrier bags, wet wipes, tobacco filters, balloons) and producers of fishing, recreational fishing and aquaculture gear containing plastic.
Primary source ↗Verified 2026-09-23
EU-CSDDD

Corporate Sustainability Due Diligence Directive (CSDDD) – Directive (EU) 2024/1760

European Union · European Commission / Member State authorities
Adopted; amended by Directive (EU) 2025/794 and Directive (EU) 2026/470 (Omnibus I, in force 18 March 2026). Transposition due 26 July 2028.

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).
Primary source ↗Verified 2026-09-23
In force since 1 January 2023; scope extended to companies with 1,000+ employees in Germany from 1 January 2024. The government bill to abolish the reporting duty retroactively and limit fines to serious violations (BT-Drs. 21/2474, cabinet decision 3 September 2025) had its first Bundestag reading on 15 January 2026 and remains in committee as of 23 September 2026. Since 1 October 2025 BAFA no longer reviews company reports under §§ 12 and 13 LkSG and imposes fines only for serious violations.

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.
Primary source ↗Verified 2026-09-23
In force since 28 March 2017 (day after promulgation 27 March 2017)

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.
Primary source ↗Verified 2026-09-23
NL-CLDDA

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

Netherlands · To be designated supervisory authority (Autoriteit Consument en Markt was originally proposed); not yet designated
Adopted by the Dutch Senate on 14 May 2019 and published in the Staatsblad, but never entered into force. As of 23 September 2026 wetten.overheid.nl lists it as a future text with no entry-into-force date. Not repealed; the government has committed that any withdrawal will be by statute, not Royal Decree (Senate commitment T02721, still open).

Covered companies would have to investigate whether child labour exists in their supply chains, adopt a plan of action where reasonable suspicion arises, and submit a one-time declaration of due diligence. Sanctions would include administrative fines and, on repeat offences, criminal liability for directors.

Enforcement
Mandatory
Effective date
Not in force as of 23 September 2026; Art. 12 provides for entry into force on a date set by Royal Decree, no earlier than 1 January 2020, and no date has been set
Covered entities
Companies that sell goods or services to Dutch end-users, regardless of where they are established. Implementing decree was to set thresholds and exemptions.
Primary source ↗Verified 2026-09-23
CH-DDTrO

Ordonnance sur les devoirs de diligence et de transparence en matière de minerais et de métaux provenant de zones de conflit et en matière de travail des enfants (DDTrO / VSoTr), RS 221.433; Code of Obligations Art. 964j–964l

Switzerland · Federal Department of Justice and Police (FDJP) and the company's audit firm; civil/criminal liability via the Federal Department of Finance for false reporting
In force from 1 January 2022; first reports required for financial year 2023, published by mid-2024. A Federal Council consultation draft (NUFG, consultation 1 April to 9 July 2026) would move these duties into a new federal act; no dispatch to Parliament published as of 23 September 2026.

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.
Primary source ↗Verified 2026-09-23