A German customer has sent an LkSG questionnaire or written LkSG clauses into a contract. You may also have read that Germany is abolishing the law. Both are true. The reform removed reporting and softened enforcement; it did not remove your customer's duty to check its supply chain. The questionnaire is a live request.
| First question | Short answer |
|---|---|
| Is the LkSG cancelled? | The reporting duty and most sanctions are gone. The due diligence duties remain in force until the CSDDD-implementing law replaces them. |
| Am I in scope? | Almost certainly not. The law binds companies with 1,000 or more employees operating in Germany. Their suppliers receive the questions. |
| Why does the questionnaire continue? | The customer still has to run risk analyses across its supply chain and document them internally. |
| What do they need from me? | Policies on human rights, safety, environment; labor records; a grievance route; a signed commitment; your own supplier expectations. |
| Do I need an LkSG compliance program? | No. Standard ESG groundwork, assembled once and reused. |
Regulation details and links checked 14 July 2026. The replacement law was still pending; the official German government LkSG page tracks the current state.
What the LkSG is
The Lieferkettensorgfaltspflichtengesetz — the German Supply Chain Due Diligence Act — requires larger companies operating in Germany (1,000 or more employees) to carry out human rights and environmental due diligence across their supply chains: a risk management system, regular risk analyses, preventive and remedial measures where risks or violations appear, a complaints channel, and documentation.
Due diligence across the supply chain necessarily includes suppliers. The law has always reached you indirectly: the customer assesses its risk by asking you questions, collecting your policies, and obtaining your commitment to standards.
What changed in 2025, and what did not
Germany's coalition government decided to repeal the LkSG and replace it with a law implementing the EU CSDDD in a deliberately "bureaucracy-light" way. Two changes have landed:
- The annual reporting obligation was abolished, retroactively. In-scope companies no longer file compliance reports. BAFA, the supervising authority, stopped reviewing reports on 1 October 2025.
- Enforcement was scaled back. Until the CSDDD-implementing law takes over, sanctions apply only to severe human rights violations, not the broader catalog of duties (reform analysis).
The core due diligence duties remain in force. In-scope German companies must still run risk management, carry out regular risk analyses, and take preventive and remedial measures. What was cancelled is the paperwork to the authority and most of the penalty regime.
The EU successor is not imminent for most companies. After the Omnibus delay, the CSDDD applies from mid-2029 for the largest companies, with others later. German customers face several years in which the LkSG duties still bind them, followed by an EU framework expecting broadly the same things.
Stopped and continuing
Stopped
- Annual compliance reports to BAFA (abolished retroactively; reviews stopped 1 October 2025)
- Sanctions for most breaches (only severe human rights violations remain sanctionable for now)
Continuing
- Risk management systems and regular risk analyses at in-scope companies
- Preventive and remedial measures across their supply chains
- Complaints and grievance channels
- Supplier questionnaires, codes of conduct, and contract clauses — the instruments through which the above is done
Why the questionnaires continue
- The due diligence duty continues. A risk analysis cannot be run without supplier data.
- Internal documentation continues. No filing to BAFA does not mean no records. Companies keep evidence of their due diligence for their boards, their auditors, and the arrival of the replacement law.
- They are converging on the CSDDD. The EU framework carries similar, in some ways broader, supply chain expectations. Customers keep their supplier assessment machinery running.
- Contracts require it. Clauses committing you to standards, cooperation, and audits do not lapse because a reporting form was switched off.
Treat an LkSG questionnaire as a current request. Expect the same requests to continue, gradually relabelled from "LkSG" to "CSDDD".
Direct scope
Almost certainly not. The obligations fall on companies with 1,000+ employees operating in Germany, not on their smaller suppliers and not on suppliers outside Germany. An SME supplier has no LkSG filing duty, no BAFA relationship, and no need for an LkSG compliance program. It has a customer who is in scope and needs assurances. The legal duty sits upstream; the requests flow down.
What the customer needs
An LkSG-driven request typically asks you to demonstrate:
- Human rights — no child or forced labor, fair wages, reasonable hours, non-discrimination, freedom of association
- Health and safety — safe conditions, policies, records
- Environmental basics — compliance with environmental obligations; sometimes specific issues named in the law, such as certain hazardous substances
- A grievance or incident channel — a documented way for workers or third parties to raise concerns
- Your own supply chain — that you pass reasonable expectations to your suppliers, often through a supplier code of conduct
- A signed commitment — acknowledgment of the customer's code of conduct or supplier standards
Responding efficiently
No LkSG regime is needed. Standard ESG groundwork, assembled once and reused:
- Core policies — human rights, health and safety, environmental, anti-corruption, supplier code of conduct. The ESG policy template guide covers what each needs to say.
- Labor documentation — evidence of fair wages, working hours, voluntary employment.
- A grievance route — however simple, written down and reachable.
- Basic supply chain awareness — where key inputs come from and who the critical suppliers are.
- Honest gap handling — where something is missing, say so and give a dated plan.
This is the foundation described in small supplier ESG requirements, answerable from a response system, which also serves IntegrityNext, the platform many German buyers use to collect exactly this data.
To gauge how much work a questionnaire represents before committing time, the free time estimator gives a figure based on what is already in place.
What not to do
- Do not assume it is cancelled. The reporting duty is gone; the questionnaires are not. An unanswered one is flagged in the customer's risk analysis.
- Do not build your own LkSG compliance regime. Answer the customer's requests instead.
- Do not invent policies or data. A fabricated answer that fails a follow-up or audit is worse than an honest gap.
- Do not treat LkSG, CSDDD, and IntegrityNext as separate projects. They ask for the same human rights and environmental facts. Answer all of them from one base.
The bottom line
Germany is repealing the LkSG and folding it into a lighter law implementing the EU CSDDD. Reporting to BAFA is abolished and enforcement is limited to severe cases, but the due diligence duties remain, so German customers still need risk data, policies, a code-of-conduct signature, and a grievance route from suppliers. Meet the request with solid groundwork; the same materials answer the CSDDD-era questionnaires that follow.