What the Act requires
The Norwegian Transparency Act (Åpenhetsloven) has been in effect since July 2022 and continues to shape how companies approach human rights due diligence in 2025. The law applies to companies that meet at least two of these criteria:
- Revenue above NOK 70 million
- Balance sheet total above NOK 35 million
- Over 50 employees on average
It also includes public interest entities (like listed companies, banks, and insurers) regardless of size.
If your company is covered, you are legally required to:
- Conduct human rights and decent work due diligence
- Publish an annual report on due diligence by 30 June
- Respond to public information requests within three weeks
These expectations apply not just to your operations, but to your full supply chain.
The six steps of due diligence
The law is based on the OECD Guidelines for Responsible Business Conduct. In 2025, regulators expect companies to follow these six steps:
- Embed human rights in company policy. Develop internal policies and assign responsibility for due diligence across the organisation.
- Map and assess risks. Identify actual and potential risks to human rights across your operations and supplier network.
- Act to prevent or reduce impact. Implement targeted actions to stop or reduce the most significant risks you've identified.
- Monitor and follow up. Track the effectiveness of your actions and update your risk assessments regularly.
- Communicate and report. Publish your due diligence findings and report on progress to stakeholders — including the annual statement required by law.
- Enable remediation. If negative impacts occur, provide or support access to remedies and document the process.
How Factlines helps you comply
Factlines’ Supplier Relationship Management (SRM) platform supports every step of the due diligence process, making it scalable, trackable, and easier to manage.
- Chain Survey: Map your supplier network. Use the Chain Survey to reach direct and indirect suppliers with digital self-assessments. Quickly collect data across tiers and geographies.
- Risk scoring and prioritisation. Automatically prioritise follow-up based on supplier risk profiles — including country, sector, and response quality.
- Follow-up and improvement actions. Assign and monitor corrective actions with built-in workflows that support remediation and accountability.
- Reporting and documentation. Export data directly for your Transparency Act report or to respond to public information requests — always audit-friendly.
What’s new in 2025?
While the core obligations remain unchanged, enforcement is increasing and companies are expected to demonstrate real progress.
In addition:
- Minor legal updates in late 2024 clarified reporting duties and scope
- Norway is working to align the law with the EU’s Corporate Sustainability Due Diligence Directive (CSDDD)
- Environmental and climate risks will likely be included in future updates
Get started with Factlines
Factlines helps you stay compliant with less manual work and more confidence. Whether you’re just getting started or ready to scale, our tools support a professional and structured approach to supply chain due diligence.
See how Factlines work. Book a demo or request a free trial today.
