The tracker · Germany

German Supply Chain Due Diligence Act

Reform proposedGermanyEntry updated October 2026

The German due diligence law that shaped supplier questionnaires worldwide, now being folded into CSDDD transposition.

Status
Reform proposed
Enacted
January 2023
First compliance deadline
January 2023 (3,000+ employees); January 2024 (1,000+)
Companies in scope
Companies with 1,000 or more employees in Germany; the coalition plans to raise this to 5,000 employees and EUR 1.5 billion in worldwide turnover
Maximum penalty
Up to 2 percent of average annual turnover for the largest companies
Civil liability
No new civil cause of action; special litigation standing for trade unions and NGOs
Enforcement body
Federal Office for Economic Affairs and Export Control (BAFA)

Latest movement

Coalition decided on 2 July 2026 to cut the scope to 5,000 employees and EUR 1.5 billion turnover from autumn 2026; the amendment bill is still unpassed.

In plain language

What this law does

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. BAFA stopped reviewing reports in October 2025 and limited enforcement to serious violations, and a bill that would abolish the reporting duty retroactively has sat before the Bundestag since January 2026 without passing. On 2 July 2026 the coalition went further, deciding to restrict the act to companies with at least 5,000 employees and more than EUR 1.5 billion in worldwide turnover from autumn 2026, and to transpose the CSDDD without going beyond it. That decision is political rather than legal, and no bill giving effect to it had appeared by October 2026. For suppliers, BAFA-driven questionnaires have already slowed, but German buyers continue to run LkSG-shaped systems as the baseline for CSDDD readiness.

Obligations

What it asks of companies

  1. Annual and ad hoc risk analysis

    Companies must analyse human rights and environmental risks annually and when the risk situation changes materially.

  2. Preventive and remedial measures

    Identified risks require documented preventive measures with suppliers and remedial action where violations occur.

  3. Complaints procedure

    An accessible grievance channel must be available to workers and affected parties throughout the supply chain.

January 2023

Act applied to companies with 3,000 or more employees.

January 2024

Threshold lowered to 1,000 employees.

April 2025

Coalition agreement announced repeal and replacement through the CSDDD transposition.

September 2025

Cabinet bill abolished the reporting duty retroactively and narrowed the fines catalogue.

October 2025

BAFA limited enforcement to serious violations and stopped reviewing reports.

January 2026

Bundestag began deliberating the amendment bill.

2 July 2026

Coalition decided to restrict the act to companies with at least 5,000 employees and more than EUR 1.5 billion in worldwide turnover from autumn 2026, and to transpose the CSDDD one to one.

October 2026

Amendment bill still not passed, and no bill yet introduced for the narrower scope.

Changelog

Entry history

October 2026

Corrected the claim that the reporting duty was removed in 2025: the bill has not passed, although BAFA stopped reviewing reports in October 2025. Added the coalition decision of 2 July 2026 to narrow the scope.

May 2026

Entry updated to track the repeal-and-replace bill and narrowed BAFA enforcement.

Trade under this regime · Regulated Trade Index

Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology

$37bn
Vietnam$9.5bnIndia$8.9bnBrazil$5.6bnThailand$5.4bnBangladesh$5.3bnIndonesia$2.8bn

Sources

Primary documents