The tracker · Germany
The German due diligence law that shaped supplier questionnaires worldwide, now being folded into CSDDD transposition.
Reporting duty removed in 2025; repeal-and-replace bill folding LkSG into CSDDD transposition advancing.
In plain language
The LkSG obliges companies with at least 1,000 employees in Germany to conduct risk analyses, adopt preventive and remedial measures, operate complaints procedures and document their due diligence across own operations and direct suppliers, extending to indirect suppliers on substantiated knowledge of risk.
The 2025 coalition agreement committed to replacing the LkSG with a lean CSDDD-implementing law. The reporting obligation was removed in 2025 and enforcement narrowed to serious violations while the replacement bill moves through the Bundestag. For suppliers, BAFA-driven questionnaires have already slowed, but German buyers continue to run LkSG-shaped systems as the baseline for CSDDD readiness.
Obligations
Companies must analyse human rights and environmental risks annually and when the risk situation changes materially.
Identified risks require documented preventive measures with suppliers and remedial action where violations occur.
An accessible grievance channel must be available to workers and affected parties throughout the supply chain.
Timeline
Act applied to companies with 3,000 or more employees.
Threshold lowered to 1,000 employees.
Coalition agreement announced repeal and replacement; reporting duty removed.
CSDDD transposition bill in parliamentary process.
Changelog
Entry updated to track the repeal-and-replace bill and narrowed BAFA enforcement.
Sources