I would like to inform you about the recent policy developments in Germany and the EU in relation to the German Supply Chain Act (LkSG) and the EU CSDDD.
LkSG
The newly elected German government reiterated that they intent to adapt the Supply Chain Act according to the requirements of EU CSDDD (see below).
Until CSDDD is implemented into national law, the German government plans to pause LkSG reporting requirements and will only sanction companies in case of very severe human rights violations – the core LkSG due diligence obligations remain in place.
EU CSDDD
The European Commission’s Omnibus Initiative foresees a one-year postponement of the CSDDD’s entry into force. Depending on company size, compliance will be required from 2028 or 2029.
The content of the directive is currently under revision. While adjustments in scope and requirements are possible, EU lawmakers have emphasized that the overall level of protection and the key due diligence principles should remain intact.
Final agreement on the revised directive is expected around Q1 2026.
Informed by Ehsan Fazlee Shamim, Executive President of BKMEA
