The LkSG reporting deadline is now 31 December 2025.
Last week, BAFA, the enforcement agency of the German Supply Chain Act (LkSG), announced that the deadline for companies to report on their due diligence in line with the LkSG has been postponed to 31 December 2025. Additionally, BAFA stated that they will not review due diligence reports or sanction companies based on disclosures until January 2026.
This delay in the reporting requirement was widely anticipated, as the German government had previously indicated its plan to avoid double reporting obligations under the LkSG and the EU Corporate Sustainability Reporting Directive (CSRD).
The timeline for LkSG due diligence requirements remains unchanged.
It’s essential for companies to note that this extension applies only to the reporting obligation. As BAFA explicitly stated in its updated FAQ on 25 October, the timeline to carry out the other due diligence obligations under the LkSG remain unchanged.
This means that companies subject to the LkSG are still required to conduct risk analyses, implement preventive measures (such policies, capacity building for employees and suppliers, and supplier assessments), take remedial actions, establish complaint procedures, and document their due diligence activities. BAFA retains the authority to sanction companies for failing to meet these obligations – even before January 2026.
The postponed deadline does not mean companies are unable to submit their LkSG reports before 31 December 2025. In fact, while BAFA will not make requests for improvement until this date, companies that choose to file their due diligence reports can receive indications from the BAFA on improving their reports. This extension effectively provides companies with a testing period to establish and refine their corporate sustainability reporting processes without risking sanctions or other legal consequences.
Misleading statements by German politicians about the LkSG’s scope and timeline, as well as its alignment with the CSRD, have fueled debates and caused confusion in the recent weeks. Companies are seeking regulatory consistency. In a joint statement issued today, the German Trade Union Federation and DAX 40 (the 40 largest public companies of Germany) highlighted that ongoing discussions around suspending the German Supply Chain Act are crearing confusion and uncertainty for companies already working to implement the law.
Companies should use this additional time for to improve sustainability due diligence.
As CORE, we welcome the alignment between the reporting obligations under the LkSG and the EU CSRD. Corporate sustainability due diligence should be simplified rather than hindered. Identifying the synergies between due diligence laws allows businesses to implement effective due diligence processes, streamlining efforts to operate in line with different corporate sustainability regulations, such as EU Deforestation Regulation, EU Battery Regulation and the US Uyghur Forced Labor Prevention Act (UFLPA). Instead of vague political statements, German and EU policymakers should aim to promote responsible business practices with clear, actionable guidance.
The core of corporate sustainability due diligence remains consistent, and establishing due diligence processes based on the UNGPS and OECD Guidelines is a smart decision that goes beyond compliance.
Implementing the LkSG due diligence requirements, including its reporting obligation now, provides companies operating in Germany with a competitive edge as they have the opportunity to test and fine-tune their due diligence processes well before EU-wide legal enforcement take effect. Ignoring this head start due to delayed deadlines and political debates would be a significant missed opportunity.
We are excited to work with organizations committed to making a difference! Contact us at hello@peopleatcore.com to discuss how you can strengthen your corporate sustainability due diligence.
Serra for the CORE team
