Companies are increasingly required to identify and act on human rights and environmental risks in their supply chains. Germany's Supply Chain Due Diligence Act applies from 1,000 German employees but is being softened; France's vigilance law applies to very large groups; the UK requires a modern slavery statement from £36 million turnover. At EU level, the corporate sustainability due diligence directive was postponed in 2025 to apply from 2028, and a forced labour product ban is coming. Mid-size groups usually meet these rules first as suppliers to larger customers.
National laws in force
Germany's LkSG applies to companies with their head office, principal place of business, registered seat or a branch in Germany that generally employ at least 1,000 people in Germany. The consolidated text provides fines of up to EUR 800,000, or 2% of average worldwide turnover above EUR 400 million. In 2025 the federal cabinet adopted a draft amending law that would abolish annual reporting retroactively and remove most fine provisions, and BAFA has stopped reviewing reports and says it will fine only serious breaches; whether the amendment has been enacted must be checked.
France requires a vigilance plan from companies that, with their subsidiaries, employ at least 5,000 people in France or 10,000 worldwide, and a person with standing can ask a court to order compliance after formal notice. The UK requires any commercial organisation carrying on business in the UK with turnover of £36 million or more to publish an annual modern slavery statement.123456
The EU directive and its 2025 postponement
Directive (EU) 2024/1760, as adopted, covers EU companies with more than 1,000 employees and net worldwide turnover above EUR 450 million, and non-EU companies with EU turnover of at least EUR 450 million. The 2025 stop-the-clock directive moved transposition to 26 July 2027 and application to 26 July 2028 for the largest groups and 26 July 2029 for the rest. Further changes to scope and obligations under the EU omnibus simplification package were not confirmed, so in-scope thresholds must be checked against the text in force.
Separately, Regulation (EU) 2024/3015 prohibits products made with forced labour on the EU market. In the US, a presidential memorandum of July 2026 directs Section 301 tariffs on goods from 60 economies found to have failed to prohibit imports made with forced labour, showing how forced labour is now handled through trade measures as well as disclosure laws.78910
| Jurisdiction | Law | Threshold | Status or sanction | Source |
|---|---|---|---|---|
| Germany | LkSG | At least 1,000 employees in Germany | Fines up to EUR 800,000 or 2% of turnover; amending law pending | gesetze-im-internet.de; BAFA |
| France | Duty of vigilance | 5,000 in France or 10,000 worldwide (with subsidiaries) | Court-ordered compliance after formal notice | portail-rse.beta.gouv.fr |
| United Kingdom | Modern Slavery Act 2015, s54 | Turnover £36 million or more | Annual statement | GOV.UK |
| European Union | CSDDD (2024/1760) | More than 1,000 employees and EUR 450 million turnover (as adopted) | Applies from 26 July 2028 or 2029 after 2025 postponement | EUR-Lex |
| European Union | Forced Labour Regulation (2024/3015) | All products placed on the EU market | In force since 13 December 2024; application date not confirmed | EUR-Lex |
| United States (federal) | Section 301 tariffs (July 2026 memorandum) | Goods of 60 economies | Tariffs of 10% or 12.5% | Federal Register |
Decisions to make
- Does any group entity meet the LkSG, French vigilance or UK modern slavery thresholds?146The thresholds differ widely, from £36 million turnover in the UK to 1,000 German employees and 5,000 French employees.
- Will the group be within the EU directive when it applies in 2028 or 2029?78Scope depends on employees and turnover over two years, and the thresholds may have been changed by later amendments.
- Which large customers will pass their due diligence obligations down the chain?17Companies below the thresholds receive supplier codes, questionnaires and audit requests from in-scope customers.
- Could any products or inputs be linked to forced labour?910The EU is prohibiting such products on its market, and the US is using tariffs against economies that do not ban them.
Documents usually needed
- Supplier map with country and sector risk ratings
- Supplier code of conduct and contract clauses on human rights and audit
- Risk analysis and remediation records
- Modern slavery statement approved by the board and published on the website
- Grievance mechanism description and case log
Common mistakes
- Assuming the EU directive already applies, or that it has been abandoned
- Counting only employees of the German entity, not group employees counted under LkSG rules
- Publishing a UK statement that has not been approved by the board
- Treating supplier questionnaires as the whole of due diligence
- Ignoring forced labour risk in lower tiers of the supply chain
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- Amendments to the CSDDD under the EU omnibus simplification package, including any changes to thresholds, civil liability or transition plans, were not confirmed; the web search budget was exhausted before this could be checked.
- Enactment and effective date of the German LkSG amending law were not confirmed.
- The application date of the EU Forced Labour Regulation was not shown on the page read.
- The US Uyghur Forced Labor Prevention Act and customs withhold release orders were not researched.
- Gulf and Indian supply chain disclosure rules (for example SEBI business responsibility reporting) were not covered.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
The Supply Chain Due Diligence Act (LkSG) applies to companies with their head office, principal place of business or registered seat in Germany, or a German branch, that generally employ at least 1,000 employees in Germany. Threshold applies from 1 January 2024 (previously 3,000). Group companies' German employees count towards the parent's headcount; agency workers count after six months.
The consolidated LkSG text provides fines of up to EUR 800,000, or up to 2% of average annual worldwide turnover for companies with turnover above EUR 400 million, for failures such as not taking remedial action. Fine levels vary by breach (EUR 100,000 to EUR 800,000). See de-risk-010 on the pending amendment.
gesetze-im-internet.de is an unofficial consolidation; it still showed this text on 18 October 2026, but enactment of the amending law could not be confirmed either way.
The Federal Cabinet adopted a draft LkSG amending law that would abolish the annual reporting obligation retroactively and remove nine of the thirteen fine provisions; BAFA has stopped reviewing company reports and says it will fine only serious violations as a last resort. BAFA notice dated 1 October 2025 describing the draft; enactment status as at October 2026 not confirmed.
Check the Federal Law Gazette for whether the amending law has been promulgated and its effective date.
A capital company with its registered office in France must establish, publish and implement a vigilance plan if, over its last two financial years, it and its French subsidiaries employ at least 5,000 people, or it and its French and foreign subsidiaries employ at least 10,000. Commercial Code, article L.225-102-4. Covers SA, SCA, SE and SAS. A French company with 5,000 or more employees whose foreign parent has not adopted a plan covering it is also covered; subsidiaries are exempt where the controlling company's plan covers them. The plan contains a risk map, assessment procedures for subsidiaries, subcontractors and suppliers, mitigation actions, an alert mechanism set up with trade unions and a monitoring system.
Official government portal; page undated. Effect of the EU Corporate Sustainability Due Diligence Directive as amended was not covered.
A company that fails to establish or publish its vigilance plan can be given formal notice with three months to comply, after which any person with standing can ask the court to order compliance under penalty payments; a company can also be held civilly liable for harm caused by a failure of vigilance. Commercial Code articles L.225-102-4 and L.225-102-5. A public buyer may exclude a company that did not establish a plan for the previous year (Code de la commande publique, article L.2141-7-1). The plan and its implementation report are included in the management report.
Official government portal; page undated. Effect of EU due diligence reforms not covered.
A commercial organisation that supplies goods or services, carries on all or part of its business in the UK and has annual turnover of £36 million or more must publish an annual modern slavery statement. Turnover includes subsidiaries and excludes VAT and trade discounts. Adding the statement to the government registry is encouraged but not required.
Directive (EU) 2024/1760 on corporate sustainability due diligence, as adopted on 13 June 2024 and in force from 25 July 2024, covers EU companies with more than 1,000 employees on average and net worldwide turnover above EUR 450 million, and non-EU companies with net turnover in the EU of at least EUR 450 million. Thresholds must be met in each of the last two consecutive financial years (EU companies) or the financial year before the last (non-EU companies); there is no employee threshold for non-EU companies. Thresholds as stated in recitals 27 to 30 of the original text.
Read from the original Official Journal text, not a consolidated version. Later amendments to scope or obligations under the EU omnibus simplification package, if adopted, were not confirmed.
Directive (EU) 2025/794 of 14 April 2025 postponed the CSDDD: Member States must transpose it by 26 July 2027, the largest EU and non-EU groups must apply it from 26 July 2028 and all other in-scope companies from 26 July 2029. Reporting under Article 16 applies for financial years starting on or after 1 January 2029 (first group) or 1 January 2030 (others). The same directive delayed CSRD sustainability reporting for later waves to financial years starting on or after 1 January 2027 and 1 January 2028.
Regulation (EU) 2024/3015 of 27 November 2024 on prohibiting products made with forced labour on the Union market entered into force on 13 December 2024. EU-wide; it also amends Directive (EU) 2019/1937. Its date of application was not shown on the page read.
Only the title and metadata were readable; the operative prohibitions (including any coverage of exports) and the date of application could not yet be checked.
A presidential memorandum of 23 July 2026 directs the US Trade Representative to impose Section 301 tariffs on all goods of 60 economies found to have failed to prohibit imports made with forced labour, at 10 percent or 12.5 percent, or on a net-of-MFN basis for the EU, Taiwan, Japan, Korea and Switzerland. Federal. Products listed in an annex are exempt; tariff-rate quotas are to be set for certain textiles and apparel from Bangladesh, Cambodia, Indonesia and Malaysia. No end date is set and USTR may modify or terminate the tariffs.
Read on the FederalRegister.gov web edition, which describes itself as unofficial; the official text is the Federal Register PDF on govinfo.gov. The effective date of the tariffs and the annex of exempt products (published as images) could not yet be checked. USTR's Section 301 page also lists other 2026 investigations, including structural excess capacity in manufacturing (initiated 11 March 2026).
Questions on this topic
10 statements on supply chain and human rights due diligence
