Latest Updates on amfori’s Work on the German Supply Chain Act



On the 22nd of July 2021, The German Human Right Due Diligence law was signed by the German President, Frank-Walter Steinmeier, and published in the Federal Official Journal. The law introduces mandatory compliance with international norms against labour exploitation.

The law lists obligations for companies above a certain size to adopt and implement due diligence procedures that prevent human rights and environmental abuses along the companies supply chain.

Failure to implement such procedures or act on violations may result in fines of up to 2 percent of the company’s international revenue. Any company found to be in violation of the law may be excluded from public procurement for up to three years.

The law applies to companies with more than 3,000 employees as of 2023, and 1,000 employees in 2024. This would ultimately result in approximately 4,800 companies being affected.

amfori has been carefully monitoring the new law as we count over 800 German members, which represents 30% of our membership and the largest country representation. Therefore, we have taken important steps to prepare our German members to the changes brought by the legislation.

How is amfori Preparing its Members?

In anticipation of the new law entering into force, in May 2021 we launched a pre-project to assess what you would need to comply with the new provisions.

The assessment included:

  • A survey and a deep-dive session to evaluate the way you use amfori tools and services
  • A due diligence journey mapping to segment our membership’s needs (e.g. whether you are directly or indirectly impacted by the law)
  • An internal benchmarking to assess the compliance of amfori tools and services with the law’s requirements (in the case that our members are using BEPI and/or BSCI fully)

The results of the internal benchmarking helped us to identify the areas in need of improvement as well as to decide what investments should be made for 2022 regarding the human rights and environmental due diligence landscape.

What Have we Learnt from the Pre-Project?

We are confident that members who use amfori BSCI, amfori BEPI fully as well as all related services such as the amfori Academy, amfori Insight, the Speak for Change programme etc. are likely to meet the provisions in the main section of the law.

amfori is taking the necessary steps to further improve, adapt and develop tools and services to raise your level of compliance regarding human rights and environmental due diligence.

We will be developing practical guidance tools to help you navigate the new law with a special focus on reporting and risk assessment, which come out as your priorities.

How Does amfori Continue to Support Your Due Diligence Journey?

amfori acknowledges the importance of the new law and is determined to provide you with the best support to ensure you are properly prepared.

We have increased our efforts and resources on this topic and have been working diligently on different solutions for you.

  • Capacity Building and Raising Awareness

We have decided to increase our capacity building and raising awareness activities on the topic and have launched a webinar series specifically on the HREDD landscape. The first of the series took place on the 24th of November and focused on the German Supply Chain. The recording is available here. More webinars will follow shortly.

  • amfori Tools and Services Review 

Furthermore, we are currently reviewing and improving our internal tools and services to make sure they offer a high level of compliancy with the new law and the upcoming European HREDD legislation more generally.

Therefore, we are:

  • Revising the current BSCI System Manual – the updated BSCI Code of Conduct will be released before the end of 2021.
  • Upgrading our major environmental tool – amfori BEPI.  More information will be shared shortly.
  • Deploying the Speak for Change programme
  • Further developing amfori Insight and the usage of your supply chain data and reporting - view our latest webinar here


  • Advocacy & Stakeholder Engagement

Engaging with governments and stakeholders will continue to be pursued to raise awareness about what you, our members, do and how amfori supports you. This will be done through the organisation of dedicated stakeholders’ events and the fine-tuning of our advocacy messaging to ensure that the reality of supply chains is well understood and that policies are designed with that understanding in mind.

If you have any questions, please contact