Who must comply with the Norwegian Transparency Act? Thresholds explained
Your company must comply with the Norwegian Transparency Act (åpenhetsloven) if you meet at least two of these three threshold requirements:
This applies to both Norwegian companies operating in Norway and foreign companies selling products or services to the Norwegian market. Approximately 9,000 companies are directly covered by these compliance obligations.
If you don't meet the thresholds, you may still be indirectly affected through customer requirements for supplier due diligence.
Annual turnover refers to your total revenue from sales of goods and services. Use figures from your most recent approved annual accounts to determine if you meet this threshold requirement.
Companies with turnover approaching NOK 70 million should consider establishing due diligence processes before crossing the threshold. This prepares your organization for compliance obligations and avoids last-minute scrambling.
Your balance sheet total is the sum of all assets, including property, equipment, inventory, receivables, and cash, shown on your balance sheet.
Even if your annual turnover stays below NOK 70 million, significant asset holdings combined with employee count can trigger transparency act compliance requirements through this threshold criterion.
The employee threshold counts full-time employees and part-time employees proportionally to their hours. The law states "50 or more full-time employees (or equivalent)."
For specific questions about calculating your employee count under åpenhetsloven requirements, consult with HR or legal advisors familiar with Norwegian employment law.
Any Norwegian company that meets at least two threshold criteria must comply with transparency act obligations. This applies regardless of your industry: manufacturing, retail, services, construction, technology, or any other sector.
The size thresholds determine compliance requirements, not your business activities or sector.
Foreign companies selling products or services in the Norwegian market must comply if they meet the threshold requirements. This includes:
The Transparency Act applies based on your business activity in Norway, not your physical location or headquarters. Foreign companies face the same compliance obligations as Norwegian businesses.
How Factlines helps: Factlines' automated documentation and AI-generated summaries help streamline the reporting process, regardless of where your company is based.
Companies meeting the threshold criteria must fulfill three main obligations:
Conduct due diligence assessments (§4): Identify and assess actual and potential adverse impacts on human rights and working conditions throughout your operations and supply chain. This follows the OECD due diligence framework.
Publish annual transparency reports (§5): By June 30 each year, publish a public report describing your due diligence process, identified risks, measures taken to address impacts, and results achieved.
Respond to information requests (§6): Answer requests from anyone (NGOs, journalists, consumers, or other stakeholders) about your human rights and working conditions due diligence within three weeks.
These compliance obligations apply once you meet the threshold requirements. The Norwegian Consumer Authority (Forbrukertilsynet) enforces åpenhetsloven through penalties and public warnings.
Forbrukertilsynet can impose significant penalties for failing to meet transparency act requirements:
Beyond financial penalties, non-compliance creates substantial reputational risks. Public failures damage trust with customers, investors, and employees. Media and NGO scrutiny intensifies when companies appear in enforcement registers or fail to respond to information requests.
If your company doesn't meet the thresholds, you're not directly required to comply with åpenhetsloven. However, smaller businesses often face indirect requirements through their customers.
Large companies conducting due diligence assessments must evaluate their suppliers as part of transparency act compliance. If your customers are above the thresholds, they'll likely require documentation from you about:
Many procurement processes now require supplier due diligence documentation before awarding contracts. Suppliers unable to provide adequate documentation risk losing business opportunities, even if they're below åpenhetsloven thresholds themselves.
Smaller companies benefit from establishing systematic due diligence processes before customer requests arrive. This allows you to respond quickly when documentation is requested, demonstrate commitment to ethical business practices, and prepare for future growth that may cross thresholds.
How Factlines helps: Suppliers get free platform access without needing their own licenses. Previous responses automatically populate new questionnaires from different customers, dramatically reducing time spent on repeated assessments while ensuring consistent answers.
The Norwegian Transparency Act aligns with broader European human rights due diligence legislation. Similar requirements exist across Europe:
Companies operating across European markets often face overlapping compliance requirements. The same due diligence processes and supplier assessments can address multiple regulations simultaneously.
Whether you're above thresholds or preparing for customer requirements, Factlines provides systematic supplier due diligence tools:
Risk assessment and mapping: Send questionnaires to suppliers identifying human rights and working conditions risks. Automatic risk scoring based on your criteria prioritizes high-risk relationships for immediate attention.
Action tracking and documentation: Register preventive and corrective measures directly in the platform. Automated reminders ensure actions are completed. All documentation receives timestamps and audit trails for transparency report preparation.
Annual reporting: AI-summaries speed up June 30 transparency report preparation. Structured data enables quick, accurate responses to public information requests within the three-week requirement.
Multi-tier supply chain visibility: Assess risks not only with direct suppliers but also through sub-suppliers. Track relationships, risk levels, and corrective actions at every tier with full documentation.
Reduced supplier survey fatigue: Suppliers reuse previous responses across multiple customer assessments. This saves time while maintaining complete documentation and ensuring consistent answers.
