The Norwegian Transparency Act requires subject companies to publicly report on the human rights due diligence they must carry out under the Act. These reports must be published every year, by June 30. With the 2025 reporting deadline looming, the Norwegian Consumer Authority has published five tips for improving this year’s reports. Those tips are discussed in this post.
Both entities resident in Norway and foreign enterprises that offer goods or services in Norway can be subject to the Act. Because the compliance thresholds are low by international standards, many US-based and other foreign multinationals are required to comply with the Act.
About the Transparency Act
This post is focused specifically on the tips recently published by the Norwegian Consumer Authority. For information about the compliance thresholds and requirements under the Act, see these Ropes & Gray alerts published in conjunction with attorneys at leading Norwegian law firm Thommessen:
Note that these alerts do not discuss minor amendments to the Transparency Act made last November that generally are not relevant to foreign multinationals.
Five Tips for 2025 Reports
As indicated above, the Norwegian Consumer Authority has published five tips for this year’s reports. These tips are informed by the Consumer Authority’s reviews of disclosures from the last two reporting cycles.
The tips were published on the Consumer Authority’s website last week. They also were distributed by email blast earlier this week.
- Covered entities. If the business is part of a group, indicate in the report which business the report applies to. The report also should be clear whether it covers multiple businesses, for example where it covers both parent and subsidiary companies.
- Reporting period. Indicate the period covered by the report so that a reader can distinguish this year's report from previous reports.
- Signature. Date and sign the report. The report is required to be signed in accordance with the Norwegian Accounting Act, as further discussed here.
- Accessibility. The report must be easily accessible on the company’s website, including easy to find.
- Combined reporting. If the due diligence assessments under the Act are included together with other reporting, indicate which parts of the report pertain to the Transparency Act. The Norwegian Consumer Authority cites as an example a sustainability report. However, for US-based multinationals, Transparency Act disclosure is most often combined with global modern slavery reporting.
The guidance will be familiar to many US-based multinationals that have reporting obligations under modern slavery transparency laws (which will be the case for the vast majority of US-based multinationals subject to the Transparency Act). Regulators have put out similar guidance in connection with modern slavery reporting.
The Norwegian Consumer Authority has carried out compliance checks in the last two reporting cycles. In conjunction with publishing the foregoing tips, the Norwegian Consumer Authority indicated that it will carry out new checks on compliance with the reporting requirements of the Act after June 30.
