LkSG — German Supply Chain Due Diligence Act

LkSG — German Supply Chain Due Diligence Act: (1) annual risk analysis identifying human rights and environmental risks in own operations and direct supplier relationships.

Jurisdiction
eu
Status
active
Category
First deadline
Substantive requirements: ongoing. Annual BAFA report: ABOLISHED Sept 2025. CSDDD (EU equivalent) must be transposed into German law by July 26, 2028.
Who must comply
Companies with ≥1,000 employees working IN Germany (branches and subsidiaries count; employee headcount combines German
Penalties
Up to €800,000 for serious breaches; up to 2% of global annual turnover for companies with >€400M global revenue. Exclusion from public procurement for up to 3 years. NOTE: BAFA now applies fines only for most serious violations; enforcement is minimal pending CSDDD transposition.

What it is

LkSG — German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz (2021)) is a eu supply chain diligence measure. (1) Annual risk analysis identifying human rights and environmental risks in own operations and DIRECT supplier relationships.

Who must comply

Companies with ≥1,000 employees working IN Germany (branches and subsidiaries count; employee headcount combines German branch + German subsidiary). Applies from January 2024. Includes German branches of foreign (including US) companies.

What you must disclose

(1) Annual risk analysis identifying human rights and environmental risks in own operations and DIRECT supplier relationships. (2) Human rights and environmental due diligence policy. (3) Preventive measures for identified risks. (4) Complaint procedure. (5) Remediation for confirmed violations. NOTE: Annual public reporting obligation to BAFA was ABOLISHED effective September 2025 — substantive due diligence processes are still required but the formal BAFA annual report is no longer required. Transition pending CSDDD transposition by July 2028.

Timeline

Substantive requirements: ongoing. Annual BAFA report: ABOLISHED Sept 2025. CSDDD (EU equivalent) must be transposed into German law by July 26, 2028.

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