Regime

Supply Chain Due Diligence Act (LkSG)

Human rights due diligence in the company's own operations and at direct suppliers, documented rather than reported.

CarteBlanche / Supply Chain Due Diligence Act (LkSG)

LkSGLegal position as of 12 October 2026

Basis
LkSG
Threshold
from 1,000 employees in Germany
Penalty
up to EUR 8 million or 2 % of global turnover
Source
IHK Nord Westfalen zum LkSG
last checked 12 October 2026 · review cycle quarterly

What is required

Risk analysis, preventive and remedial measures, a complaints procedure and internal documentation kept for seven years. The annual reporting duty has been dropped.

What has to be done

  • one-offAdopt and publish a policy statement on the human rights strategy.
  • one-offAssign responsibility, for example by appointing a human rights officer, and anchor it in the management body.
  • annualCarry out a risk analysis in the company's own operations and at direct suppliers, annually and for cause.
  • ongoingEmbed preventive measures and take remedial action where violations are identified.
  • annualSet up a complaints procedure, publish the rules of procedure and review its effectiveness annually.
  • ongoingDocument compliance on an ongoing basis and keep the documentation for seven years.

Stages over time

All companies in scope

  1. Date of application from 1,000 employees

Sections 10(2) to (4) LkSG, the reporting duty, were repealed retroactively to 1 January 2023; the due diligence duties remain.

Criteria checked

  • 1,000 employees or more in Germany

Check this for your own company

Legal position as of 12 October 2026All nine regimes