What is the
norwegian transparency act
Also known as: Åpenhetsloven
The Norwegian Transparency Act (åpenhetsloven) entered into force on 1 July 2022. It requires larger enterprises to conduct due diligence to identify and address adverse impacts on human rights and decent working conditions — within their own operations and throughout their supply chains.
How does the Norwegian Transparency Act work?
The Act is modelled on the OECD Guidelines for Multinational Enterprises and imposes three main obligations:
- Due diligence (Section 4): Enterprises must identify adverse impacts on human rights and working conditions, and take measures to cease, prevent, or mitigate them. The obligation covers all tiers of subcontractors, not just direct suppliers.
- Duty to account (Section 5): An annual account of due diligence findings must be published by 30 June each year.
- Right to information (Sections 6–7): Anyone may request information about how an enterprise handles adverse impacts, with a three-week response deadline.
The Act applies to enterprises meeting at least two of three criteria: annual revenue exceeding NOK 70 million (approx. EUR 6 million), total assets exceeding NOK 35 million, or more than 50 full-time equivalents. The Norwegian Consumer Authority enforces the Act with fines of up to four per cent of annual revenue or NOK 25 million.
Impact on public procurement
In Norway, the Public Procurement Act already requires contracting authorities to promote human rights in procurement. The Transparency Act strengthens this by providing a concrete standard that authorities can reference when evaluating suppliers. Non-compliance may constitute grounds for rejection, and in cases of forced labour or child labour, rejection is mandatory.
The EU's Corporate Sustainability Due Diligence Directive (CS3D) will impose comparable obligations across the EEA. Tools like Cobrief can help suppliers track tenders where social procurement and due diligence requirements are central.
The Norwegian Transparency Act links corporate human rights responsibility directly to public procurement. For suppliers seeking public contracts, due diligence is increasingly both a legal obligation and a competitive necessity.