The tracker · Germany
The German due diligence law that shaped supplier questionnaires worldwide, now being folded into CSDDD transposition.
Reporting abolished and fines narrowed; due diligence duties remain in force pending CSDDD transposition.
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 through the CSDDD transposition.
Cabinet bill abolished the reporting duty retroactively and narrowed the fines catalogue.
BAFA limited enforcement to serious violations and stopped reviewing reports.
Bundestag began deliberating the amendment bill.
Changelog
Entry updated to track the repeal-and-replace bill and narrowed BAFA enforcement.
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
Sources