What is the Transparency Act? [...]

Various international guidelines already impose requirements for due diligence and transparency, but these are voluntary. Certain of these requirements are now a legal obligation under the Transparency Act.

The Transparency Act entered into force on 1 July 2022.

Who does the Transparency Act apply to?

• Larger enterprises that are resident in Norway and that offer goods or services in or outside Norway
• Larger foreign enterprises that offer goods or services in Norway, and that are liable to tax to Norway pursuant to internal Norwegian legislation (Sections 2 and 3).

It is estimated that the law will apply directly to around 9000 enterprises...

What does the Transparency Act impose on companies?

The Transparency Act requires enterprises to conduct due diligence assessments, meaning that they must look at both their own business, their supply chain and their business partners to find out where the biggest risks are (Section 4)...

Should the whole supply chain be included in the assessment?

In principle yes, but the company should prioritize the due diligence based on several factors, including the severity and probability of any adverse impact...

The enterprise shall publish an account of the due diligence assessments...

Any person has the right to information from a company regarding how the company addresses actual and potential adverse impacts uncovered by its due diligence (Section 6).

«Any person» means anyone e.g., other businesses, public bodies, civil society organizations, journalists and the general public...

Both the request for information and the answer must be in writing. The deadline is within a reasonable time and no later than 3 weeks after the request is received. A longer deadline of 2 months is allowed if the amount or type of information requested makes it disproportionately burdensome to respond within 3 weeks...

The Norwegian Consumer Authority (Forbrukertilsynet) monitors compliance with the provisions of the Act.