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Norway | Effective: 2022

Norway Transparency Act

A simple guide on how to successfully comply with the Norwegian human rights due diligence law

The Transparency Act applies to larger enterprises resident in Norway and larger foreign enterprises that offer goods or services in Norway or are liable to tax in the country. Larger enterprises are defined as those that meet or exceed the thresholds for two of the following three conditions:

  • 50 full-time employees (or equivalent annual man-hours)
  • An annual turnover of NOK 70 million
  • A balance sheet of NOK 35 million

Due diligence in line with OECD Guidelines

The Act doesn’t deviate substantially from international standards, such as OECD Guidelines and the UN Guiding Principles on Business and Human Rights, although it’s more demanding in terms of supply chain coverage – companies need to conduct due diligence throughout their business relationships, in a manner appropriate to their type, size, sector, and operational context.

Human rights reporting requirement

Companies are also required to transparently disclose how they follow up with their human rights responsibilities: Those in scope must publish an annual human rights statement on a company website, after it has been signed off by all Board members.

Reporting entities should also be able to transparently communicate their due diligence efforts and findings on an individual request. In practice, it means that any member of the public can ask for such details. The right to request information is a unique aspect of the Norwegian Transparency Act – there’s no such provision in German or French due diligence laws, nor in the EU CSDDD proposal.