German NGOs reject draft bill to amend national Supply Chain Act
'The Supply Chain Act must not be weakened!'
Unofficial Resource Centre translation of a statement by the German Supply Chain Act Initiative ('Initiative Lieferkettengesetz') on the Federal Labour Ministry's draft bill to amend the Supply Chain Due Diligence Act (LkSG)
In its draft bill to amend the Supply Chain Due Diligence Act (LkSG), the Federal Ministry of Labour proposes a massive weakening of the LkSG by abolishing both reporting obligations and sanctions for key elements of due diligence. This undermines the stronger protection of human rights and the environment in supply chains worldwide that has finally been achieved.
We therefore reject the draft bill and call on the Federal Government and the Bundestag not to adopt the proposed amendments to the law.
A weakening of the LkSG is also not necessary insofar as the European due diligence directive [CSDDD] would require the reintroduction of sanctions that are now to be abolished. What companies need instead is continuity and planning security. This is confirmed, among other things, by a survey conducted by Jaro Institute, according to which companies are more concerned with reducing bureaucracy in areas other than the LkSG, such as lowering energy costs or speeding up planning and approval procedures...
The extremely short consultation period of less than 24 hours is in sharp contrast to the importance of human rights and environmental protection issues...
The draft significantly weakens the [supervisory authority] BAFA's ability to impose sanctions for breaches of due diligence obligations. It is particularly worrying that missing or incomplete risk analyses would no longer be considered an administrative offence. This undermines the preventive power of the law in particular...
The proposed abolition of reporting obligations should also be rejected... Alignment with the obligations under the European reporting directive CSRD should take place, but only once it is clear whether these will be sufficient to meet the requirements of the LkSG...
...A weakening of the LkSG is... contrary to the prohibition of deterioration or regression in the protection of human rights enshrined in European and international law.
See also: 'Initiative Lieferkettengesetz' press statement (in German) of 3 September 2025