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VSME vs. the Transparency Act (Åpenhetsloven): What’s the Difference?

VSME and the Transparency Act (Åpenhetsloven) serve different purposes, but work best together: VSME structures ESG and supplier data, making it easier for companies to carry out the human rights due diligence required by law.

 The Transparency Act (Åpenhetsloven) sets clear expectations: companies must carry out due diligence, identify human rights risks, and take action across their supply chains.

 The challenge? Getting the right data from suppliers.

 This is where VSME becomes useful. VSME is not a legal requirement, but a structured reporting framework that helps suppliers share consistent and relevant information. It gives companies a clearer picture of who their suppliers are, how they operate, and where potential risks may lie.

Area VSME data point Information provided Relevance to Åpenhetsloven
Company structure & operations B1 – General information Business activities, organization and locations Supports the general company description under §5(a) and provides context for due diligence
Value chain & suppliers C1 – Business model & value chain Value chain structure, suppliers, sectors and geographical exposure Supports the mapping and assessment of actual and potential negative impacts under §4(1)(b)
Policies & practices B2 & C2 – Practices, policies & future initiatives Policies, practices, targets and sustainability initiatives Relevant to embedding responsibility in company policies under §4(1)(a)
Human rights & due diligence C6 – Human rights policies & processes Human rights policies, codes of conduct and due diligence processes Supports the identification, prevention and management of human-rights risks under §4
Workforce B8 – Workforce characteristics Workforce composition and employee information Provides context for assessing working conditions and human-rights risks
Wages & labour rights B10 – Remuneration, collective bargaining & training Wages, gender pay gap, collective bargaining and training Relevant to decent working conditions, including living wages and labour rights under §3(c)
Health & safety B9 – Health & safety Workplace accidents, fatalities and safety information Relevant to health, safety and working conditions under §3(c) and §4(1)(b)
Non-standard workers C5 – Self-employed & temporary workers Information on temporary, agency and self-employed workers Supports assessment of working conditions and human-rights risks
Human rights incidents C7 – Severe human rights incidents Confirmed incidents involving issues such as child labour, forced labour and discrimination Supports identification and reporting of actual negative impacts under §4(1)(b) and §5(b)
Measures & monitoring C2 – Actions, targets & initiatives Actions, targets and progress addressing identified risks Supports measures and monitoring under §4(1)(c)–(d) and reporting under §5(c)

 

In simple terms:
VSME helps you get the data you need, so you can actually do the work the Transparency Act requires.VSME can support compliance by providing useful data on suppliers, such as company structure, policies, workforce conditions, and potential human rights risks. However, it does not replace the legal requirements to assess, act, and document measures under the Transparency Act.

Below is a simplified comparison:AreaVSME data pointInformation providedRelevance to ÅpenhetslovenBottom line: by using VSME, companies can:

  • Standardize supplier data collection
  • Gain insight into risk areas such as geography, workforce, and labor conditions
  • Identify red flags early, including lack of policies or reported incidents
  • Build a stronger foundation for due diligence assessments

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