European Due Diligence Laws: Beyond the LkSG

Germany's Supply Chain Due Diligence Act (LkSG) gets the most attention, but it is one instance of a broader European shift: human-rights and environmental due diligence is becoming a legal duty across multiple jurisdictions, each with its own statute. For any company selling into Europe — or supplying someone who does — the practical question is not "does the LkSG apply to me" but "which of this growing family of laws applies, and can one program satisfy them all."

The encouraging answer is that, beneath the differing detail, these laws ask for the same thing. Build the capability once and you are most of the way to compliance with all of them.

Norway's Transparency Act (the Åpenhetsloven) requires larger enterprises to carry out human-rights and decent-work due diligence across their supply chains, aligned with the OECD Guidelines — and, distinctively, to publish an account of it and to answer information requests from the public. That public-facing element raises the stakes: your due diligence is not just for a regulator, it is answerable to anyone who asks, on a deadline.

For procurement, the operational implication is that you must be able to describe, on demand and with evidence, what you know about risks in your supply chain and what you have done about them — which is only feasible if that knowledge is maintained continuously rather than assembled reactively.

France's Duty of Vigilance law (the devoir de vigilance) was an early mover, requiring large companies to establish and implement a "vigilance plan" identifying and preventing severe human-rights and environmental impacts across their operations, subsidiaries, and established suppliers. It is notable for its enforcement edge: it opened the door to civil liability, and French courts have entertained cases pressing companies on the adequacy of their plans.

The message from the French experience is that a due-diligence plan is judged on substance, not paperwork. A vigilance plan that identifies risks it never actually monitors is exactly the kind of gap litigation targets.

Line the laws up and the overlap is obvious. The LkSG's §2 catalogue, Norway's OECD-aligned due diligence, France's vigilance plan, and the EU's CSDDD all require the same four things: know your suppliers and sub-tiers, assess them against defined human-rights and environmental risks, act on what you find, and document it in a form you can produce on demand. The wording and the enforcement differ; the underlying evidence does not.

That is why chasing each law separately is the wrong approach. A single continuous, supplier-level due-diligence capability — discover the network, monitor it against the risk catalogue, convert findings into owned and logged actions — produces the evidence all of these regimes ask for, and positions you for the ones still arriving. To see how one program can serve the LkSG, the Norwegian and French laws, and the CSDDD at once, request a demo, or read the LkSG guide in the Risk Center.