LkSG · Germany · law in transition
The German Supply Chain Act was trimmed. Your German customer’s questions were not.
The reporting duty towards the authority has fallen away; the core duties on risk analysis, prevention and documentation have not. If you supply into Germany, you will still be asked – just without the detour through an official report.
The Lieferkettensorgfaltspflichtengesetz has applied to large German companies since 2023. In 2025 the federal government stopped report reviews and moved an amendment that removes the reporting duty. In the medium term the LkSG will be replaced by Germany’s implementation of the EU due diligence directive, due in national law by the end of July 2028.
One point survives all of this untouched: obligated companies must know their risks, and they only know them if their suppliers answer. The questionnaire keeps coming – it is simply called a supplier self-disclosure rather than a report.
Who is affected
- German companies with 1,000 or more employees in Germany – directly obligated.
- Their Swiss suppliers – through contracts, codes of conduct and self-disclosures.
- Companies with German group entities whose staff may count towards the threshold.
The duties that remain
- § 4
- Adequate risk management with clear internal ownership.
- § 5
- Regular and event-driven risk analysis in the own business area and at direct suppliers.
- § 6
- Preventive measures, notably contractual assurances, training and risk-based controls.
- § 7
- Remedial action where violations are found, with a concept and a timeline.
- § 8
- A complaints procedure open to people outside the company.
- § 10
- Continuous internal documentation, retained for seven years.
How SCRM covers it
Supplier self-disclosures
Send questionnaires digitally, store answers on the supplier record, surface the gaps.
Risk analysis with reasoning
Assessments by country, sector and commodity group – traceable, repeatable, versioned.
Contractual assurances
Codes and confirmations with validity and reminders instead of a shared drive.
Actions and deadlines
Remediation recorded with an owner and a date, history available at any time.
Frequently asked
Has the act been abolished?
No. The reporting duty towards the authority is gone and supervision is more restrained. The substantive due diligence duties and internal documentation duty continue until the successor regime takes effect.
We are a Swiss SME. Does this concern us?
Not as an obligated party. Very much as a supplier: your German customer must analyse its suppliers and will pass questionnaires, codes and evidence duties on to you.
Is the effort worth it if the law is changing anyway?
The legal basis changes, the data does not. Whoever holds suppliers, countries, commodity groups and evidence in structured form answers any successor regime faster than with a fresh spreadsheet.
As of July 2026. The legal position is in transition; verify before relying on it. Not legal advice.