The Norwegian Transparency Act (åpenhetsloven) requires companies to conduct due diligence assessments, act on identified risks, and publish a public due diligence report each year. With deadlines approaching (June 30th), it is critical to ensure your reporting is structured, complete, and compliant.
This checklist covers the essential steps for preparing and publishing your due diligence account correctly.
How to prepare and publish a due diligence report under the Norwegian Transparency Act (åpenhetsloven)
1. Understand your obligations before starting
Before beginning work on the due diligence report (redegjørelse), ensure you understand the core requirements:
▪️ Conduct due diligence assessments of your own operations and business relationships.
▪️ Act on prioritised risks and findings.
▪️ Publish a public account each year describing your due diligence activities, findings, and actions taken to address risks.
Your report must provide:
▪️ A description of your organisational structure, business areas, products, and services.
▪️ An overview of your ethical guidelines and policies for human rights and decent working conditions.
▪️ A description of procedures, procurement practices, contract management, and complaint mechanisms in place to handle human rights risks.
Compliance with the Transparency Act (åpenhetsloven) ensures that your company's efforts are transparent, traceable, and aligned with Norwegian legal standards.
Download our FREE template for due diligence reporting here!
2. Conduct due diligence assessments
Perform systematic due diligence assessments across your operations and supply chains. This involves:
▪️ Identifying potential and actual negative impacts on human rights and decent working conditions.
▪️ Assessing the severity and likelihood of these impacts.
▪️ Prioritising the most severe risks for action.
3. Summarise due diligence findings and streamline reporting
After completing your due diligence assessments, summarise key findings clearly:
▪️ Highlight identified risks and affected business areas.
▪️ Describe steps taken to address or mitigate risks.
▪️ Using AI-assisted tools, such as Factlines AI, helps save time by generating structured summaries, improving efficiency, and ensuring your findings are consistent.
4. Implement actions and follow up
Beyond identifying risks, companies must take action:
▪️ Implement measures to cease, prevent, or mitigate adverse impacts.
▪️ Track the implementation and effectiveness of actions taken.
▪️ Maintain records of follow-up activities for transparency and accountability.
5. Board approval, signing, and publication
Before publishing the due diligence report:
▪️ Have the report reviewed by the board of directors.
▪️ Ensure it is dated and signed according to the company’s official signing rights (prokura).
▪️ If the report covers multiple companies, each entity’s board must separately process and sign.
Publication tips:
▪️ Publish this year's report in the same location as last year's to ensure traceability for customers and authorities.
▪️ The report must be written in Norwegian unless your company is formally exempt.
Make it easy for users and the Norwegian Consumer Authority (Forbrukertilsynet) to find the report by using the phrase "account of the due diligence assessments"(redegjørelse) in the title and online publishing.
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Factlines SRM software simplifies due diligence and reporting under the Norwegian Transparency Act (åpenhetsloven). Manage risk assessments, document findings, streamline board approvals, and ensure publication compliance, all within one platform designed for accuracy, collaboration, and long-term transparency.
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