Published: April 8, 2025
In recent years, Norway’s Transparency Act has become a cornerstone in the promotion of responsible business conduct and sustainable practices. The law imposes clear requirements on larger enterprises to map and publicly report how they work with human rights and decent working conditions – both within their own operations and across their supply chains.
In a new article published on April 7, 2025, the Norwegian Consumer Authority announces that it is intensifying its monitoring of companies' compliance with the duty to report – one of the key obligations under the Act. This move comes ahead of the next deadline: June 30, 2025.
What does the duty to report entail?
All enterprises covered by the Transparency Act – that is, large companies meeting specific thresholds – are required to publish an annual report detailing their due diligence assessments. This involves identifying and addressing actual and potential adverse impacts on human rights and working conditions, and disclosing the measures taken in response.
This report must:
Be published annually and updated no later than June 30 each year
Be easily accessible via the company’s website
Provide public insight into how the company assesses and manages risk in its value chain
This is more than a formality. The reporting obligation is a tool to build trust between companies and society – giving consumers, partners, and investors real insight into corporate responsibility efforts.
What does the Consumer Authority say in its latest article?
The Consumer Authority emphasizes that inspections will continue and that companies are expected to be well underway with their due diligence processes. According to Director Bente Øverli, publishing these assessments in accordance with the reporting obligation should now be a natural part of the work.
Initial inspections began in 2023, shortly after the June 30 deadline. More than 500 companies were reviewed, and over 100 received guidance on how to comply with the law. The follow-up inspections in 2024 revealed disappointing results: several companies had violated the law two years in a row.
Fines – and legal uncertainty in the Act
Based on these findings, the Consumer Authority issued advance notices of administrative fines ranging from NOK 550,000 to 2,500,000 against six companies. This made it clear that the Authority was willing to use sanctions to ensure compliance.
At the same time, legal uncertainty has emerged around how certain terms in the Act should be interpreted. In February 2025, the Market Council reviewed a case in which the Authority had imposed a fine of NOK 450,000 for failure to respond to an information request. The Council overturned the decision, citing uncertainty as to whether the condition of “repeated violations” had been met, since only two breaches had occurred.
As a result, the Consumer Authority decided to close the six reporting-related cases without fines – despite confirmed violations. However, this does not absolve companies of responsibility; rather, it underscores the need for clearer legal provisions – and possibly legislative amendments.
Enforcement continues – and obligations still apply
It’s important to note that the Consumer Authority has not backed down – quite the opposite. Inspections will continue, and companies that fail to meet their obligations still face guidance, enforcement penalties, and fines.
As Øverli states:
"Companies that lack a report on their website are in breach of the law."
This sends a clear message to Norwegian companies: it’s time to take the Transparency Act seriously – not just to avoid penalties, but to meet growing expectations around corporate responsibility and sustainability.
What should companies do now?
If you represent a company subject to the Transparency Act, now is the time to:
✅ Conduct or update your due diligence assessments
✅ Write and publish your report by June 30, 2025
✅ Ensure the report is easily accessible on your website
✅ Understand your obligations and how to comply
This work is not just about meeting legal requirements – it’s about being part of a future where transparency and accountability are expected, not optional.
👉 Forbrukertilsynets artikkel: Kontrollerer redegjørelsesplikten i åpenhetsloven
👉 Veiledning om redegjørelsesplikten på forbrukertilsynet.no