Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
Update, 4 November 2026: this article describes the situation at the time of publication. Under Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, operators must comply from 30 December 2026. Micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. Downstream operators and traders of any size must comply from 30 December 2026 and do not submit due diligence statements. Responsibility does not rest with the upstream operator alone: under Articles 5 and 7, downstream operators and traders must collect and keep the reference numbers where their supplier is an operator, and keep records. For the current state, read What actually happens on 30 December 2026.
The European Commission has announced a new proposal designed to support companies, third countries, and Member States in preparing for the EU Deforestation Regulation (EUDR). The proposal introduces targeted simplifications, updated entry-into-application dates, and transitional measures to ensure a smoother rollout of the law.
The Commission stated that these adjustments will help guarantee that the EUDR’s central IT system is fully operational before mandatory reporting begins and will reduce administrative burden for smaller operators while maintaining the regulation’s core objectives.
Key EUDR measures in the proposal
Simplified DDS obligations for smaller and downstream operators
The proposal introduces several simplifications to make compliance more practical across the supply chain:
Downstream operators and traders that commercialise products already placed on the EU market will no longer be required to submit individual due diligence statements. Responsibility for compliance will rest with the upstream operator placing the product on the market for the first time.
Micro and small primary operators from low-risk countries will submit only a one-time declaration in the EUDR IT system, rather than repeated submissions. When equivalent data is already available in a national database, no additional submission will be required.
According to the Commission, these adjustments could reduce administrative costs by approximately 30 percent.
Updated compliance implementation timeline
The proposal confirms that the EUDR will still apply to large and medium companies from 30 December 2025, but introduces a six-month grace period for checks and enforcement.
For micro and small enterprises, the application date would move to 30 December 2026.
The revised timeline is intended to give the IT system more time to scale to the higher-than-expected volume of due diligence statements. The Commission also noted that contingency measures are being developed in case the new proposal is not adopted before the end of 2025, in which case the current deadlines would remain in force.
Next steps
The proposal will now move to the European Parliament and the Council for review and formal adoption. The Commission has urged both institutions to adopt the amendment by the end of 2025 to ensure legal certainty for all stakeholders.
What this means for businesses
The Commission’s proposal provides greater clarity, but it also removes any justification for delay. Many companies have paused their EUDR preparation in recent months, assuming enforcement would be postponed. This new update makes it clear that large and medium enterprises must still comply from 30 December 2025.
This leaves very limited time for businesses to prepare, build supplier traceability, and implement compliance systems before the law takes effect. The six-month grace period applies only to enforcement checks, not to the obligation to meet EUDR requirements.
Companies that continue waiting risk falling behind, while those that act now can turn EUDR compliance into a competitive advantage.
EUDR compliance is not only a regulatory responsibility but also a signal of reliability to customers, investors, and supply chain partners. Being ready on time shows that your company can adapt, lead, and maintain trust in a fast-changing regulatory environment.
Now is the time to return to preparation, restart internal projects, and re-engage suppliers. Delays in readiness today could mean business disruption tomorrow.
How EUDR Passport supports compliance
EUDR Passport helps businesses and their supply chain partners meet these requirements through a secure, efficient, and affordable platform:
- Pay per product profile, from €90 a year with unlimited DDS and no upfront fees
- Guided workflows for every compliance step
- Supplier collaboration tools for data collection and reuse
- Direct DDS submission to the EU Information System
EUDR Passport is designed to make compliance manageable, whether the final deadline remains December 2025 or shifts to 2026.
Learn more about EUDR Passport
Related reading: what changed in the EU Deforestation Regulation since December 2025 for the current state of play, and EUDR Passport to prepare whatever the date.
Looking for EUDR software? EUDR Passport collects your supplier data, runs the risk assessment and files unlimited due diligence statements, from €90 per product profile per year.
30 DECEMBER 2026
FREE EUDR Obligations Checker: Answer a few simple questions and get an instant assessment of your EUDR obligations.