The Norwegian Transparency Act 2026: Complete guide for businesses
The Norwegian Transparency Act (åpenhetsloven) requires companies to actively address human rights violations and poor working conditions in their operations and supply chains. Approximately 9,000 Norwegian companies are directly covered, with many more indirectly affected through customer requirements.
The Norwegian Consumer Authority enforces the law and can impose fines up to 4% of annual turnover or NOK 25 million, whichever is higher.
The Act applies to companies operating in Norway that meet size thresholds, plus foreign companies selling in the Norwegian market.
Your company must comply if you meet at least two criteria:
Smaller businesses may be indirectly affected. If your customers must comply, they'll likely require documentation of your due diligence as part of their own compliance.
Identify and assess actual and potential adverse impacts on human rights and working conditions throughout your value chain. Follow the OECD's six-step due diligence process:
How Factlines helps: Send structured questionnaires to suppliers for systematic risk mapping. Automatic risk scoring prioritizes where to focus resources.
By June 30 annually, publish a public transparency report describing:
The report must be in Norwegian, board-approved, signed, and publicly accessible on your website.
How Factlines helps: Documentation is automatically stored with audit logs and timestamps. AI-generated summaries across your supply chain make annual reporting quick. No scrambling through spreadsheets before deadlines.
Anyone can request information about how you address actual or potential adverse impacts on human rights and working conditions. You must respond within three weeks.
Requests may come from NGOs, journalists, or consumers. Your response often becomes public.
How Factlines helps: Structured data enables quick, precise responses. Full traceability across suppliers, risk assessments, and measures in one platform.
Fines up to 4% of annual turnover or NOK 25 million, whichever is higher. Public warnings published in the enforcement register amplify reputational damage.
Reactive crisis management costs more than prevention: emergency audits, external consultants, legal advisors, potential supplier changes. You risk losing business opportunities as B2B customers increasingly require documented compliance before contracts.
Public failure damages trust with customers, investors, and employees. Media scrutiny intensifies when companies appear in the Consumer Authority's public register or NGO reports.
The Norwegian Transparency Act aligns with broader European human rights regulation:
Factlines covers multiple regulations. Use the same supplier data across different requirements with ready-made questionnaires for CSDDD, EUDR, and other frameworks.
1. Assess coverage. Check if you meet two of three size criteria. Consider whether customers will require documentation even if not directly covered.
2. Establish governance. Determine responsibility for due diligence. Embed human rights in relevant policies.
3. Map your value chain. Identify direct suppliers. Assess how deep you need to go based on risk.
4. Conduct risk assessments. Send structured questionnaires. Industry, geography, and previous incidents indicate risk level.
5. Implement measures. Register preventive and corrective actions. Set up follow-up and monitoring.
6. Document continuously. Collect documentation throughout the year. This makes June 30 reporting manageable.
Risk assessment: Questionnaires identify human rights and working conditions risks. Automatic scoring prioritizes high-risk relationships.
Action tracking: Register preventive and corrective measures in the platform. Automated reminders ensure completion. All documentation timestamped with audit trails.
Reporting: AI-generated summaries across your supply chain speed up annual reports and information requests. Structured data enables three-week response times.
Multi-tier visibility: Assess risk with direct suppliers and sub-suppliers. Track relationships, risk levels, and actions at every tier.
Reduced survey fatigue: Suppliers reuse responses across customer assessments. Saves time while maintaining complete documentation.
The Transparency Act requires year-round systematic work, not last-minute June 30 scrambling. Start structured mapping and documentation early.
Factlines helps 200+ organizations comply with the Transparency Act and other due diligence requirements across Europe. The platform updates with regulatory changes so you focus on conducting assessments, not interpreting legal texts.
