Your Norwegian customer has sent you a due diligence questionnaire. Here is what the law requires of them — and what they need from you.
The Åpenhetsloven (Transparency Act) came into force in Norway in July 2022. It requires large Norwegian companies — and large foreign companies selling into Norway — to conduct human rights and decent work due diligence across their entire supply chain. If you supply goods or services to a Norwegian buyer, they are legally required to assess you. Your response to their questionnaire forms part of their compliance record, which the Norwegian Consumer Authority (Forbrukertilsynet) can inspect at any time.
Key regulations in Norway — Åpenhetsloven Supplier Guide
Åpenhetsloven — The Norwegian Transparency Act
The Åpenhetsloven requires larger Norwegian enterprises and large foreign enterprises selling into Norway to embed responsible business conduct, map and assess human rights and decent working conditions risks across their supply chain, implement measures to address those risks, and publish an annual account of their due diligence. The law follows the OECD Guidelines for Multinational Enterprises. Due diligence is risk-based and proportional — the depth of assessment depends on the severity and likelihood of adverse impacts.
Forbrukertilsynet — Norwegian Consumer Authority (Enforcement Body)
Forbrukertilsynet is the Norwegian authority responsible for enforcing the Transparency Act. It can issue orders requiring companies to comply, and impose fines for non-compliance. Any member of the public, trade union, or journalist can submit a formal information request to a covered company — and the company must respond within three weeks. This public right of inquiry creates ongoing reputational and legal pressure on your Norwegian buyer to maintain thorough supplier records.
CSDDD — EU Corporate Sustainability Due Diligence Directive
Norway is an EEA member and closely aligned with EU regulation. As CSDDD comes into force across the EU, Norwegian companies will face equivalent or stricter obligations. Suppliers who can already respond to Åpenhetsloven questionnaires will be well positioned for the wave of CSDDD-driven questionnaires that will follow from EU buyers across the continent.
What this means for you as a supplier
You are not directly regulated by the Åpenhetsloven. But your Norwegian buyer is. The law explicitly states that companies covered by the Act may place demands and expectations on their suppliers as part of their due diligence process. A non-response or a weak response increases your buyer's regulatory risk — and makes you a liability in their supply chain. Forbrukertilsynet can inspect your buyer's supplier records at any time, and any member of the public can formally request information about how your buyer manages its supply chain. Your compliance evidence is part of their answer.
Key dates
1 July 2022
Åpenhetsloven comes into force — large Norwegian companies and qualifying foreign companies must comply
30 June annually
Annual due diligence account must be published on the company's website
Within 3 weeks
Companies must respond to any public information request about their due diligence
February 2026
Forbrukertilsynet publishes updated guidance — companies should review their frameworks
July 2029
CSDDD Phase 1 — EU-wide supply chain due diligence for largest companies; Norway closely aligned
2029
CSDDD Phase 3 — companies with ≥1,000 employees across EU and EEA
Which companies are required to comply
The Åpenhetsloven applies to larger enterprises — Norwegian or foreign — that meet two of the following three thresholds: sales revenue above NOK 70 million, balance sheet total above NOK 35 million, or an average of more than 50 full-time employees. Foreign companies selling goods or services into Norway that meet these thresholds and are liable to Norwegian tax are also covered.
As a supplier, you may not meet these thresholds yourself — and you are not directly regulated by the Act. But the companies buying from you almost certainly do meet them. The law explicitly anticipates this: covered companies are expected to place due diligence demands on their supply chain. Your questionnaire is the mechanism through which they do that.
What your Norwegian buyer's questionnaire will ask
Åpenhetsloven due diligence follows the OECD Guidelines for Multinational Enterprises. Questionnaires typically cover the following areas. The more structured evidence you can provide, the lower the risk your buyer carries — and the stronger your supplier relationship.
Human rights policy
A written policy covering forced labour, child labour, freedom of association, and non-discrimination. Must be endorsed by senior management and communicated to your workforce.
Decent working conditions
Evidence of fair wages, reasonable working hours, and safe conditions. The Åpenhetsloven specifically includes the right to a living wage as a core standard.
Health & safety
Workplace safety policies, incident records, and relevant certifications such as ISO 45001 or equivalent. Evidence that safety standards are maintained for all workers including temporary and contract staff.
Grievance and reporting mechanism
A formal process for workers and stakeholders to raise concerns without fear of retaliation. This may be an internal channel or a third-party whistleblowing service.
Environmental management
Basic evidence of environmental practices — waste management, emissions tracking, and any relevant certifications (ISO 14001, EMAS). The Åpenhetsloven focuses on human rights but buyers increasingly include environmental questions alongside it.
Your own supply chain due diligence
Evidence that you assess your own suppliers for human rights and decent work risks. This is the Tier 2 question — your buyer must show Forbrukertilsynet that they have checked whether their suppliers manage their own supply chains responsibly.
The public right of information — unique to Norway
The Åpenhetsloven includes a provision that has no direct equivalent in LkSG or the UK Modern Slavery Act: any person — a consumer, journalist, trade union, or NGO — can submit a formal information request to a covered company asking how they address adverse impacts in their supply chain. The company must respond within three weeks.
This means your Norwegian buyer's supply chain practices are potentially subject to public scrutiny at any time — not just during a regulatory audit. A buyer who cannot demonstrate thorough supplier due diligence faces both regulatory and reputational risk. Suppliers who provide clear, structured evidence make that response easier. Suppliers who cannot are a liability in a public information request as much as in a Forbrukertilsynet inspection.
What happens if your response is inadequate
- →Your buyer flags you as a higher-risk supplier in their annual due diligence account
- →The Åpenhetsloven requires your buyer to implement measures to address identified risks — which may mean requesting remediation from you, or sourcing from a supplier who can demonstrate compliance
- →If Forbrukertilsynet inspects your buyer and finds gaps in supplier documentation, your buyer faces enforcement orders and fines
- →If a public information request is submitted about your buyer's supply chain, your lack of documented due diligence becomes part of a public record
- →As CSDDD comes into force, the same questions will arrive from buyers across the EU — not just Norway
Forbrukertilsynet enforcement: the pressure behind the questionnaire
The Norwegian Consumer Authority enforces the Åpenhetsloven. It can issue orders requiring companies to comply, impose fines for non-compliance, and inspect a company's due diligence records at any time. Updated guidance was published in February 2026, signalling continued active enforcement. This is why your Norwegian buyer takes supplier questionnaires seriously.
| Obligation | Consequence of non-compliance | Enforcement body |
|---|---|---|
| Conduct due diligence | Enforcement order + fine | Forbrukertilsynet |
| Publish annual due diligence account by 30 June | Enforcement order + fine | Forbrukertilsynet |
| Respond to public information requests within 3 weeks | Enforcement order | Forbrukertilsynet |
| Provide accurate information (no misleading responses) | Fine | Forbrukertilsynet |
Source: Forbrukertilsynet (Norwegian Consumer Authority), updated February 2026
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received an Åpenhetsloven questionnaire?
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