LkSG complaint procedure: a practical guide for non-German companies

The German Supply Chain Act (Lieferkettensorgfaltspflichtengesetz, or LkSG) requires companies with at least 1,000 employees in Germany to set up a complaint procedure — the Beschwerdeverfahren — that lets people affected by their supply chain raise concerns about human rights and environmental risks. The procedure must be publicly accessible, allow concerns to be raised confidentially, and protect complainants from retaliation. If your company isn't German but sells to, sources from, or has a subsidiary tied to a company in scope, the LkSG can reach you too, most often through your German customers' supplier requirements.

A common misconception in 2026 is that the LkSG has been scrapped. It hasn't. Germany removed the annual reporting obligation and signaled that the act will eventually be replaced by a national law implementing the EU CSDDD, but the core due diligence duties, including the complaint procedure, remain in force. This guide explains what the complaint procedure requires, what changed recently, and how non-German companies can comply without building a Germany-only system.

Does the LkSG apply to my company?

Directly, the LkSG applies to companies with their central administration, principal place of business, or a registered branch in Germany and at least 1,000 employees in Germany.

Indirectly, and this is what catches most non-German companies, the law's due diligence obligations cascade through the supply chain. If you supply a German company that is in scope, expect:

• contractual clauses requiring you to respect human rights and environmental standards
• requests to provide information and evidence about your own operations and suppliers
• a requirement to give your workers and affected communities access to a complaint channel, either yours or your customer's

You don't need a German legal entity to feel the LkSG. You need a customer who has one.

What changed in 2025 and 2026

Three developments matter, and they pull in slightly different directions.

The reporting obligation was removed. Germany abolished the LkSG's annual due diligence report to the Federal Office for Economic Affairs and Export Control (BAFA). BAFA has confirmed it stopped routinely reviewing company reports and now focuses enforcement on serious violations.

The substantive duties stayed. Risk analysis, preventive and remedial measures, and the complaint procedure all remain mandatory. Enforcement attention has shifted from paperwork to outcomes. Auditors increasingly want evidence of a functioning complaint procedure and genuine remediation, not a filed report.

A transition toward the CSDDD is underway. Germany's governing coalition has committed to replacing the LkSG with a less bureaucratic law implementing the EU CSDDD. Until that happens, the LkSG applies as written.

The practical message: don't relax your complaint procedure because the report disappeared. The complaint procedure is exactly where enforcement is now concentrated.

What the LkSG complaint procedure must do

To meet the Beschwerdeverfahren requirement, your complaint procedure needs to satisfy the following.

Be accessible to affected people. It must be available to your own employees and to people in your supply chain, including at indirect suppliers where you have substantiated knowledge of a possible violation. Accessibility means the right languages, the right channels, and clear public information about how to use it.

Allow confidential and protected reporting. Complainants must be able to raise concerns confidentially, and the procedure must protect them from retaliation or disadvantage. For supply chain workers who are often the most exposed, anonymous reporting with secure follow-up is the most reliable way to deliver this.

Follow published rules of procedure. The LkSG expects you to publish clear, understandable rules: who is responsible, how a complaint is handled, what the steps are, and what complainants can expect. The process must be impartial, and the people running it must be independent and not bound by instructions from those who might be implicated.

Enable dialogue and remediation. The procedure should allow discussion of the facts with the complainant and lead to remedial action where a violation is found or likely. A complaint that is logged and forgotten doesn't meet the standard.

Be reviewed and effective in practice. You must review effectiveness at least once a year and whenever you expect a significant change or expansion in your risk situation. "Effective" means actually used and trusted. A channel that never receives a complaint may signal that workers don't know about it or don't trust it, not that everything is fine.

How non-German companies should approach it

You don't need a separate German system. You need one mechanism that satisfies the LkSG's requirements and scales to your wider footprint and to the incoming CSDDD. A few recommendations:

Build once, comply broadly. A single grievance mechanism that meets the UN Guiding Principles' effectiveness criteria will generally satisfy the LkSG, the French Duty of Vigilance Law, and the CSDDD, because they share the same foundation.

Localize for your actual supply chain, not for Germany alone. Multilingual, multi-channel intake (web, mobile, phone, voice) reaches workers and communities wherever they are.

Document everything. Structured, time-stamped case records give you the evidence of a functioning procedure that BAFA and your German customers now ask for.

Make it discoverable. Publish your rules of procedure and run awareness campaigns at supplier sites. Accessibility is a legal requirement, not a marketing afterthought.

Supply chain grievance software lets international organizations meet the Beschwerdeverfahren requirement without a Germany-specific build. SpeakUp Report provides anonymous, multilingual intake, an impartial case management workflow, remediation tracking, and the audit-ready record that shows your complaint procedure is working.

Note: this article is a general guide, not legal advice. LkSG obligations and the transition to a CSDDD-implementing law are evolving. Confirm your current obligations with qualified legal counsel.

Frequently asked questions

Does the LkSG apply to non-German companies? Directly, the LkSG applies to companies with 1,000 or more employees in Germany. Indirectly, its due diligence and complaint-procedure expectations cascade to non-German suppliers through their in-scope German customers' contracts and supplier requirements.

Has the LkSG been abolished? No. The annual reporting obligation to BAFA has been removed and the act is expected to be replaced eventually by a German law implementing the EU CSDDD, but the core duties, including the complaint procedure, remain in force.

What is the Beschwerdeverfahren? It is the LkSG's required complaint procedure: an accessible, confidential channel that lets people affected by a company's supply chain raise human rights and environmental concerns, with protection against retaliation and a published, impartial process.

Do I need a separate complaint procedure for Germany? No. A single grievance mechanism that meets the UNGP effectiveness criteria can satisfy the LkSG alongside the CSDDD and other due diligence laws, which is more efficient than maintaining country-specific channels.

Need a complaint procedure that satisfies the LkSG and the incoming CSDDD at once? Book a demo.