Norwegian Transparency Act (LOV-2021-06-18-99)

Act relating to enterprises' transparency and work on fundamental human rights and decent working conditions (Transparency Act).

Norwegian Transparency Act (LOV-2021-06-18-99)

The Norwegian Transparency Act will impact around 900 companies, requiring them to disclose information about their supply chains

Iselin Nybø, Norway’s Minister of Trade and Industry

How do you provide evidence in the Norwegian market that your products are being manufactured under fair working conditions?

Requirements introduced by legislation

The Norwegian Transparency Act aims to promote enterprises’ respect for fundamental human rights and decent working conditions:

  • Companies are required to conduct due diligence on their own operations and supply chains.
  • Companies must publish an annual statement detailing their efforts to identify and address such risks.
  • The statement must be made publicly available on the company’s website and submitted to the Norwegian authorities for review.

Who must comply

Companies registered in Norway, and foreign companies that must pay taxes in Norway, that meet at least two of three criteria:

  • At least 50 full-time employees.
  • An annual turnover of at least NOK 70 million.
  • A balance sheet sum of at least NOK 35 million.

Key law specifications

  • Application of appropriate measures to cease, prevent or mitigate adverse impacts.
  • Tracking of the implementation and results of the measures.
  • Communication with affected stakeholders and rights-holders regarding how adverse impacts are addressed.

Penalties for non-compliance

  • The Norwegian government introduced a regulation in February 2023, enabling infringement penalties. Penalties can reach the greater of 4% of the enterprise’s annual turnover or NOK 25 million.
  • While the regulation allows for substantial penalties, it is anticipated that the maximum fine may not be imposed during the early stages of compliance.
  • The actual fine imposed is contingent upon the specific circumstances, reflecting a nuanced approach to enforcement based on the details of each case.

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Timeline for its entry into force and compliance

By June 30 annually

Report on due diligence

The duty to publish an annual account of the due diligence process by 30 June each year.

July 2022

Entry into force

The Transparency Act enters into force in Norway.

June 2021

Norwegian Parliament adopts the Transparency Act

Obligating comprehensive human rights and decent work due diligence for large and mid-size companies across their entire value chain.

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