German Supply Chain Act (LkSG) 2026: what applies, and what is changing?

Since 1 January 2024, the Act has applied to companies with their head office, principal place of business, administrative seat or registered office in Germany and, as a rule, at least 1,000 employees in Germany, and likewise to companies with a branch under Section 13d of the German Commercial Code of that size (Section 1(1) LkSG). Within a group, the employees of group companies are attributed to the parent company (Section 1(3)).

Smaller suppliers are affected indirectly: their customers must take preventive measures towards direct suppliers (Section 6(4)) – for example taking human rights and environmental expectations into account when selecting them, obtaining contractual assurances of compliance, providing training and agreeing on controls.

Section 3(1) LkSG lists the due diligence obligations: establish risk management, assign internal responsibility, carry out regular risk analyses, issue a policy statement, embed preventive measures in the company's own business and towards direct suppliers, take remedial action, set up a complaints procedure, address risks at indirect suppliers, and document compliance (Section 10(1)) and report on it (Section 10(2)).

The Federal Government adopted a bill on 3 September 2025 (Bundestag printed paper 21/2474). It abolishes the reporting obligation in Section 10(2) to (4) retroactively as of 1 January 2023 and reduces the offences subject to fines to four – on preventive and remedial measures and on the complaints procedure.

The Bundestag held the first reading on 16 January 2026 and referred the bill to the Committee on Labour and Social Affairs. There has been no committee recommendation, no second and third reading and no promulgation so far. Until then, the LkSG applies in its current version.

On 1 October 2025, the Federal Office for Economic Affairs and Export Control announced that it no longer reviews company reports; fines are only to be imposed for serious violations involving particularly grave human rights abuses. Reports can no longer be submitted through the BAFA portal. This does not mean the reporting obligation has been repealed by law.

Directive (EU) 2026/470, published on 26 February 2026, amends the EU Corporate Sustainability Due Diligence Directive (EU) 2024/1760. It will cover EU companies with more than 5,000 employees and more than €1.5 billion in worldwide net turnover; for companies from third countries, turnover in the EU counts. Member States must transpose it by 26 July 2028; the rules apply from 26 July 2029. There is no German transposition bill yet.

The due diligence obligations apply regardless of how the legislative procedure ends. Risk analysis, supplier assessment and documentation therefore continue; the documentation obligation under Section 10(1) would remain even under the bill. Collecting supplier information in a structured way also prepares a company for the CSDDD if it falls within its scope.

In the Vendo4u catalog, dedicated criteria on sustainability and supply-chain due diligence cover the information customers typically request under the LkSG, including evidence such as a code of conduct or a policy statement. Buyers filter by them and file the profiles with the export in their own documentation.