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German DDG and Supply Chain Act LkSG

We provide LkSG-conformant master data drawn from every import clearance we handle for you: structured supplier records, countries of origin, transit routes and product-group assignments. You send us your supplier list plus risk-country list — you receive a customs-mapped LkSG data output ready for your risk analysis and BAFA report. We coordinate with your compliance team on scope, data format and delivery cadence. The DDG (German Digital Services Act implementation, in force since 14 May 2024) is a separate regime for digital service providers; we cover it on this page solely to delineate it from LkSG.

What it is about

On this page we separate two regimes that often get confused: LkSG (German Supply Chain Due Diligence Act, applicable from 1,000 employees) and DDG (German Digital Services Act implementation, for digital service providers). For our clients LkSG is the primary concern — and even there we are not the addressee but the data supplier. We coordinate with your compliance team on the customs-side input: supplier master data, countries of origin, transit countries and product groups from your imports. We address the DDG only for delineation purposes, because we hear the question regularly in client conversations.

LkSG - German Supply Chain Due Diligence Act

  • LkSG of 16 July 2021, in force since 1 January 2023.
  • Initially for companies established in Germany with at least 3,000 employees.
  • Since 1 January 2024 for companies with at least 1,000 employees.
  • Also covers German branches of foreign companies above the relevant thresholds.
  • Supervisory authority: Federal Office for Economic Affairs and Export Control (BAFA).

Core obligations under LkSG

  • Set up a risk management system to identify, prevent, end and mitigate risks.
  • Designate internal responsibility (e.g. a human rights officer).
  • Conduct regular risk analyses along the supply chain - at least annually and on a cause-related basis.
  • Issue a policy statement on the human rights strategy.
  • Embed preventive measures in the company's own business area and at direct suppliers.
  • Complaints procedure for affected persons with clear responsibilities and confidentiality.
  • Documentation and reporting obligation: annual LkSG report to BAFA, publication on the company website.
  • Where there is substantiated cause: risk analysis also at indirect suppliers.

Protected legal positions under LkSG

  • Prohibition of child labour (minimum age, prohibition of worst forms).
  • Prohibition of forced labour and slavery.
  • Prohibition of discrimination in employment and occupation.
  • Right to freedom of association and collective bargaining.
  • Prohibition of withholding an appropriate wage.
  • Prohibition of disregarding occupational health and safety.
  • Protection against unlawful land grabbing.
  • Prohibition of certain environmental risks (Minamata Convention on mercury, Stockholm POPs Convention, Basel Convention).

Sanctions under LkSG

Sanction framework for your compliance team to size: up to EUR 800,000 per individual case; for annual turnover above EUR 400 million, up to 2 percent of average annual turnover over the last three financial years; plus exclusion from public procurement for up to three years. BAFA holds audit powers and can order corrective measures. We deliver the customs-side BAFA-report input — legal assessment, risk classification and submission remain with your compliance team and legal counsel.

DDG - German Digital Services Act implementation

  • DDG of 6 May 2024, in force since 14 May 2024.
  • Implements the EU Digital Services Act (DSA, Regulation (EU) 2022/2065) at national level and complements it.
  • Largely replaces the German Telemedia Act (TMG) for the due diligence of digital services; data protection provisions of the TMG have been integrated into the TTDSG.
  • Addressees: providers of intermediary services, hosting services, online platforms and search engines.
  • Competent authority: Federal Coordinator for Digital Services at the Federal Network Agency (Digital Services Coordinator).

Obligations under DDG

  • Transparency requirements: clear disclosure of T&Cs, moderation decisions, advertising practices.
  • Notice-and-action procedures: mechanisms for reporting illegal content.
  • Obligation to clear T&Cs and user-friendly complaint and dispute resolution options.
  • Due diligence obligations tiered by service type; very large platforms and search engines (VLOPs/VLOSEs) have stricter obligations directly under the DSA.
  • Reporting obligations to the competent authority.

Connection to customs and logistics processes

We are not an addressee of LkSG — but we sit directly at the data source: every import clearance we handle produces structured records for supplier, country of origin, transit countries, product group and quantity. Exactly the fields your risk analysis needs. We prepare and deliver this data so your compliance team can ingest it directly into your risk management system — per shipment, per supplier, per quarter. You define the risk indicators; we deliver the customs-relevant LkSG output mapped to those indicators.

How we support you

  • Provision of structured supplier and route data from customs processes for LkSG risk analyses.
  • Adjustment of checklists and import/export processes to capture additional compliance flags (high-risk countries, critical product groups).
  • Cooperation with our customers' compliance teams to link customs and LkSG data.
  • Interface between customs systems and supply chain compliance tools (e.g. mapping supplier - country - risk indicator).
  • Notes on new or changed risk indicators from the EU sanctions and foreign trade perspective.
Request LkSG advice Talk to us: 02828 9039920

Frequently asked questions

We work through the thresholds with you: LkSG applies from 1,000 employees in Germany (since 1 January 2024), including German branches of foreign companies, with temporary agency workers counted from six months of assignment. If you sit below that threshold, LkSG can still cascade through your customers' Tier-1 requirements — in that case too, we deliver the customs-relevant LkSG data output you need to answer their questions.
Tier 1 is your direct contractual partners, Tier 2/3 the upstream actors. Due diligence obligations apply primarily to your own business area and Tier 1; deeper into the supply chain only on substantiated cause. In the customs declarations we handle for you, Tier 1 (shipper, supplier) is regularly visible — and often also the country of origin reaching back into Tier 2/3. We deliver these fields to your compliance team in structured, ready-to-ingest form.
We extract supplier, country of origin, transit countries, product group and quantity from every import clearance we process — precisely the fields your LkSG risk indicators require. Example: you source cotton from a high-risk country — it appears in the import declaration as origin plus tariff number, and we deliver it to you as a structured per-shipment record. You receive customs-mapped LkSG data output you can ingest directly into your risk management system.
The German alignment with the EU CSDDD is under discussion; no adopted statute exists, a draft is expected during 2026. From client practice we recommend: carry CSDDD fields in parallel with the LkSG dataset already today — then the later transition is configuration, not migration. We already structure the customs-side LkSG output to be CSDDD-compatible, so you receive a data set that works for both regimes.
The DDG is the German companion legislation to the EU Digital Services Act (DSA), in force since 14 May 2024. It applies to hosting services, online platforms and search engines and largely replaces the TMG. We address it here because the abbreviation is regularly confused with a planned German Diligence Duty Act (a supply chain regime). For your customs clearance the DDG is not relevant to us — we are not a digital service provider in the DDG sense, and we do not provide DDG compliance services.
Up to EUR 800,000 per individual case; for companies with annual turnover above EUR 400 million, up to 2 percent of average annual turnover over the last three financial years; plus exclusion from public procurement for up to three years. We deliver the customs-side data record your compliance team needs to document due diligence and support the BAFA report.