The Transparency Act: What Is Required of Your Business in 2026?

Three Years On: The Transparency Act Has Taken Shape — and Enforcement Has Tightened in Practice

Norway was an early mover. When the Transparency Act entered into force in 2022, Norwegian companies became some of the first in Europe to face a clear legal obligation to assess the risk of human rights violations and poor working conditions—not only in their own operations, but deep into their supply chains.

Three years on, the picture is clearer. An official evaluation from 2025 shows that awareness has increased, but that implementation in many companies is still too superficial. Statements are generic, supply chains are mapped without real prioritization, and too little results in actual change. The Norwegian Consumer Authority has tightened its enforcement approach—and the EU is moving ahead with CSDDD, which will impose even stricter requirements once implemented into Norwegian law.

What is the Transparency Act?

The Transparency Act—formally the Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions—entered into force on 1 July 2022. It is a Norwegian law administered by the Norwegian Consumer Authority, and it is based on the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights (UNGP).

The core of the law is simple: companies must understand their risk of contributing to violations of human rights and decent working conditions—in their own operations, among suppliers, and with business partners. And they must act on what they find. 

Who does the law apply to?

The law applies to larger enterprises domiciled in Norway, or offering goods and services in the Norwegian market. A “larger enterprise” means that at least two of the following three criteria are met:

♦  Sales revenue above NOK 70 million
♦  Total assets above NOK 35 million
♦  An average of more than 50 employees

Listed companies are always covered, regardless of size. An estimated 9,000 businesses in Norway fall directly under the law—but many more are indirectly affected because their customers impose requirements on them.

 

Three main obligations

1. Due diligence assessments (§ 4)
The company must identify and assess actual and potential adverse impacts on human rights and working conditions—throughout the supply chain. A general supplier list is not enough. The law expects you to prioritize based on risk, implement measures, and follow up.

2. Public statement (§ 5)
No later than 30 June, the company must publish a public statement on its website. It must describe the company’s methodology, which risks have been identified, and what measures have been implemented. The statement must be signed by the board of directors and the CEO.

3. Duty to provide information (§§ 6–7)
Anyone has the right to ask your company how it handles the risk of human rights violations. A response must be provided within three weeks. Any refusal must have a legal basis and be justified in writing.

What is new in 2025–2026?

Evaluation of the law (June 2025).

The Ministry of Children and Families completed an official evaluation of the Transparency Act in June 2025. The conclusion: the law has strengthened attention to human rights and working conditions, but there are still challenges related to resource use, practical guidance, and overlap with other reporting requirements. The evaluation lays the groundwork for a possible future revision of the law.

Revised guidance from the Norwegian Consumer Authority (December 2025).
The Authority published updated guidance on due diligence assessments. It offers more concrete advice and clarifies in particular that:

- A risk-based approach is sufficient—you do not need to review every supplier in detail
- General questionnaires sent to all suppliers are poorly targeted; prioritization should focus on areas of higher risk
- Deeper mapping is expected where there are indications of high risk (geography, sector, raw materials)

Stricter enforcement.
The Norwegian Consumer Authority has carried out thematic inspections in areas including textiles, sports and leisure equipment, and supply chains with a risk of forced labour. The Authority places emphasis on real findings and concrete measures—not polished policies.

Link to the EU: CSDDD.
The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) entered into force in the EU in 2024 and is on its way into Norwegian law. When that happens, it will likely trigger a revision of the Transparency Act—with deeper requirements, civil liability, and an obligation for the largest companies to adopt a climate transition plan. Norwegian businesses should prepare for requirements to increase in step with the implementation of EU regulation.

Common mistakes — and how to avoid them

Many companies are making an effort, but still missing the mark. The most common weaknesses in transparency work are:

♦ The statement is too generic—it describes procedures, not actual findings
♦ Suppliers in tier 2 and beyond are not addressed
♦ Formal errors
♦ No clear routine for responding to information requests within three weeks

A practical next step

Do you have an updated statement ready by 30 June? Do you know which suppliers in your value chain represent the highest risk? And do you have an internal process for handling information requests? These three questions are a good place to start. Feel free to get in touch - we can help you turn your work on the Transparency Act into something that creates real value, not just compliance.

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Sources: The Transparency Act (2022), revised guidance from the Norwegian Consumer Authority (December 2025), the Ministry of Children and Families’ evaluation of the Transparency Act (June 2025), OECD Guidelines for Multinational Enterprises.