Åpenhetsloven 2026: How to conduct Aktsomhetsvurderinger and prepare your redegjørelse
Last updated: December 2025 | Information verified against Forbrukertilsynet official guidance and åpenhetsloven §§4-6
The Norwegian Transparency Act (Lov om virksomheters åpenhet og arbeid med grunnleggende menneskerettigheter og anstendige arbeidsforhold, or åpenhetsloven) requires covered companies to conduct due diligence assessments (aktsomhetsvurderinger) and publish an annual account (redegjørelse) by June 30. This public report must document your systematic work to identify, prevent, and mitigate human rights and decent working conditions risks across operations and supply chains.
This guide explains the complete reporting process and clarifies exactly how Factlines software handles the operational compliance work, from aktsomhetsvurderinger to redegjørelse publication, while identifying what requires management judgment and board oversight.
While åpenhetsloven contains 15 paragraphs covering everything from the law's purpose and scope (§§1-3) to supervision, enforcement, and penalties (§§7-15), three paragraphs establish what covered companies must actively do to comply. This is where Factlines provides direct support:
§4 - Duty to conduct aktsomhetsvurderinger (due diligence assessments)
Systematically identify and assess actual and potential adverse impacts on human rights and working conditions across operations, suppliers, and business partners following the OECD Guidelines' six-step framework. This includes embedding responsibility in policies, mapping impacts, implementing measures, monitoring results, communicating with stakeholders, and providing remediation where required.
§5 - Duty to publish a redegjørelse (annual account)
Publish a board-approved public account by June 30 each year describing your aktsomhetsvurderinger processes, findings, prioritized risks, and measures taken to address them. The report must be easily accessible on your website and signed according to accounting law requirements.
§6 - Right to information
Respond to public information requests within three weeks, providing specific details about how you address particular actual or potential negative impacts. Anyone can request information about how your company handles human rights and working conditions risks related to specific products or services.
The remaining paragraphs (§§1-3, 7-15) define the law's purpose, who it applies to, what terms mean, how Forbrukertilsynet supervises compliance, and what penalties apply for violations. Your annual redegjørelse preparation focuses primarily on fulfilling §§4-6.
According to Forbrukertilsynet (the Norwegian Consumer Authority), your annual transparency report under åpenhetsloven must contain:
Organizational structure and ownership, business areas, products and services offered, geographic markets and operational locations, and key supplier relationships.
With Factlines, your supplier database automatically maintains this information with geographic risk mapping and relationship hierarchies, making it easy to generate an accurate overview for your report.
Human rights policies and ethical guidelines, procedures for identifying and addressing risks, procurement practices and supplier requirements, and complaint mechanisms and whistleblower channels.
Factlines' policy document library tracks all versions with automated distribution to suppliers and acknowledgment records, providing the documentation trail needed for this section.
Description of your systematic due diligence approach, risk assessment methodology and criteria, summary of identified actual and potential adverse impacts, prioritization of most severe and likely risks, actions taken to cease, prevent, or mitigate negative impacts, and follow-up and effectiveness tracking of implemented measures.
This is where Factlines provides the most comprehensive support: complete documentation of supplier assessments, AI-powered risk scoring, automated prioritization matrices, corrective action plan tracking with deadlines and responsible parties, and progress monitoring with timestamped audit trails that flow directly into your report narrative.
Map your supplier base (leverandørkjede), identify potential and actual negative impacts through risk mapping (risikokartlegging), assess severity and likelihood, and prioritize the most significant risks requiring immediate action.
How Factlines handles §4 aktsomhetsvurderinger:
Automated supplier questionnaires (leverandørspørreskjema): Send customized due diligence questionnaires to hundreds of suppliers simultaneously with automated reminders and response tracking. Reduces manual supplier outreach by 80%.
AI-powered risk scoring and prioritization: Questionnaire responses automatically generate human rights and working conditions risk scores based on 30+ factors including country risk, industry sector, workforce composition, audit history, and certifications. Instantly identifies high-risk suppliers requiring immediate follow-up.
Geographic risk mapping (risikokartlegging): Integration with global human rights indices (ITUC Global Rights Index, Freedom House, US State Department reports) automatically flags high-risk sourcing countries across your leverandørkjede.
Multi-tier supply chain visibility: Map and assess risks not only with direct suppliers but also subsuppliers, crucial since human rights risks often exist deeper in the supply chain.
Historical tracking and trend analysis: Multi-year assessment history showing risk trend analysis for each supplier relationship, essential for demonstrating continuous improvement in your annual redegjørelse.
What requires manual judgment:
According to åpenhetsloven §4c, companies must implement appropriate measures to stop, prevent, or limit negative impacts. This requires developing corrective action plans (CAPs), working with suppliers on improvements, monitoring implementation progress, and evaluating effectiveness as required by §4d.
How Factlines handles this:
CAP management: Create, assign, and track corrective action plans with automated deadline reminders and escalation workflows.
Supplier collaboration: Suppliers access their CAPs, upload evidence of improvements, and communicate progress through the platform.
Progress tracking: Real-time status updates and completion percentages across your entire supplier base.
Evidence documentation: All supplier-submitted documentation automatically timestamped and stored as audit trail evidence.
Effectiveness monitoring: Follow-up questionnaires automatically triggered based on CAP completion to verify lasting improvement.
What requires manual judgment:
Compile your aktsomhetsvurderinger findings into the required public account with clear methodology descriptions, key findings, implemented measures, and follow-up tracking. Your redegjørelse for aktsomhetsvurderinger must meet all Forbrukertilsynet requirements for the June 30 deadline.
How Factlines handles §5 redegjørelse preparation:
AI-assisted transparency report generation: Factlines AI analyzes your year's §4 assessment data and generates structured redegjørelse drafts covering all Forbrukertilsynet requirements based on documented activities. AI integration summarizes results across your entire supply chain, making report preparation significantly faster.
Automated compliance summaries: Statistics on suppliers assessed, risk categories identified across your leverandørkjede, corrective actions implemented, and completion rates formatted for your annual transparency report.
Pattern synthesis across supply chain: AI summarizes patterns across supplier responses (e.g., "23% of textile suppliers in Bangladesh reported overtime compensation challenges") rather than requiring manual analysis of hundreds of questionnaires.
Template compliance with åpenhetsloven krav: Report drafts follow Forbrukertilsynet's structural requirements with all mandatory content elements per §5, including organization description, policies, aktsomhetsvurderinger methodology, findings, and measures taken.
Multi-year comparison for continuous improvement: Automatic year-over-year comparisons showing progress in risk reduction and supplier improvement, demonstrating your systematic approach to human rights due diligence.
Åpenhetsloven §5 requires that the redegjørelse be signed in accordance with accounting law rules. Present the draft transparency report to your board of directors, obtain formal approval through board resolution, and date and sign according to company signing authority (prokura). Each legal entity's board must separately approve if reporting for multiple companies covered by åpenhetsloven.
How Factlines supports board approval:
Board-ready export packages: Export polished transparency report drafts with supporting data appendices formatted for board review and decision-making.
Version control and document management: System maintains all draft versions with timestamps showing iterative refinements based on feedback and revisions.
Åpenhetsloven §5 requires that the redegjørelse be made easily accessible on your website. Publish in the same location as previous year's transparency report for consistency, use clear terminology ("redegjørelse for aktsomhetsvurderinger") in page title and URL, ensure Norwegian language unless your company is formally exempt from Forbrukertilsynet, and publish by the June 30 deadline (åpenhetsloven frist).
How Factlines supports publication:
Export formats: Publication-ready PDF and web-optimized versions with proper formatting and accessibility features.
Checklist verification: Built-in publication checklist confirms all required elements before export.
Factlines supplier risk management software supports the operational work required to comply with åpenhetsloven krav, particularly for §4 aktsomhetsvurderinger and §5 redegjørelse preparation. The platform automates supplier data collection, risk assessment and documentation, corrective action tracking, and transparency report generation, allowing you to meet the June 30 deadline systematically.
The strategic work that remains
While Factlines handles the operational burden of data collection, risk scoring, and documentation, certain aspects of åpenhetsloven compliance require management judgment:
Factlines ensures that when your leadership makes these critical judgment calls, they're based on complete, systematically documented data with full audit trails, not incomplete spreadsheets or gut feelings. The platform eliminates the time-consuming operational burden so your team can focus on strategic decisions that genuinely require human expertise.
Factlines supplier risk management software automates the operational work required for Norwegian Transparency Act compliance, from supplier aktsomhetsvurderinger and corrective action tracking to redegjørelse generation and audit documentation. Focus your team's time on strategic decisions while Factlines handles the time-consuming compliance tasks.
Contact us to learn more or book a demo today. You can also request a free trial if you want to test our software.
Download our free redegjørelse template to see what your annual report should include.
Missing the åpenhetsloven reporting deadline constitutes non-compliance with §5. Forbrukertilsynet can issue warnings and impose overtredelsesgebyr (violation fees) up to 4% of annual turnover or NOK 25 million (whichever is higher) per åpenhetsloven §14. Publish as soon as possible if delayed, document the reasons, and notify the Consumer Authority proactively to demonstrate good faith compliance efforts.
No. Åpenhetsloven §5 requires that the transparency report be in Norwegian. Companies can publish supplementary English versions for international stakeholders, but the legally required redegjørelse for aktsomhetsvurderinger must be Norwegian. This requirement is explicitly stated in the law.
Yes. If you have multiple Norwegian legal entities covered by the size thresholds, each entity's board must separately approve and sign a report. You can coordinate content across entities, but formal approval must be completed separately for each.
Stating zero identified risks signals inadequate due diligence. Every supply chain has inherent risks based on geography, industry, and workforce composition. Your redegjørelse should explain your assessment methodology and findings—even if no critical risks requiring immediate action were identified, document lower-level risks being monitored.
Your published transparency report should describe risk categories, affected business areas, and measures taken without necessarily naming individual suppliers. However, you must maintain detailed internal documentation of specific suppliers and risks in your Factlines system to respond to §6 information requests (rett til informasjon). Balance transparency requirements with protecting commercial relationships and supplier privacy. Forbrukertilsynet expects sufficient detail to demonstrate genuine aktsomhetsvurderinger without compromising competitive information.
Yes. When someone submits an information request under åpenhetsloven §6, Factlines' documentation system allows you to quickly retrieve all relevant supplier assessments, risk scores, corrective action plans, and evidence related to the specific impact mentioned in the request. The system's audit trails and timestamped documentation provide the detailed information needed to draft accurate responses within the three-week deadline required by åpenhetsloven §7. However, the actual response drafting and stakeholder communication requires human judgment.
Supplier non-response is itself a risk indicator under åpenhetsloven §4. Factlines tracks response rates and sends automated reminders through the leverandørspørreskjema system. If suppliers remain non-responsive after follow-up, this should be documented as a risk requiring alternative assessment methods such as desk research, third-party audits, or relationship review. The system helps you document your good-faith efforts to gather information, which Forbrukertilsynet considers when evaluating compliance. Non-cooperation may indicate suppliers have something to hide regarding human rights or working conditions.
Åpenhetsloven §4 covers your direct operations and "business relationships" (forretningsforbindelser), which Forbrukertilsynet interprets broadly to include suppliers, subsuppliers, joint ventures, and investments where adverse impacts may be linked to your operations. Practically, most companies focus deepest assessment on Tier 1 suppliers, with graduated approaches for lower tiers based on risk severity and likelihood. Factlines supports multi-tier supplier mapping to manage this complexity, crucial since human rights risks often exist deeper in the supply chain where visibility is limited.
No software can guarantee legal compliance, åpenhetsloven requires genuine aktsomhetsvurderinger efforts, not just documentation tools. Factlines ensures you have systematic processes, complete documentation, and audit trails demonstrating good-faith compliance. Final compliance depends on your company actually conducting assessments, taking action on findings, and exercising appropriate judgment.
