Accenture x Sourcemap on Achieving EUDR Readiness

Unpacking the Proposed EU Deforestation Delay: What Companies Should Do to Ensure They Don’t Get Left Behind This transcript summarizes a panel discussion between Marissa Brock (Senior Director of Policy and Government Affairs at SourceMap) and Miodrag Mitik (Principal Director of Strategy and Consulting for Sustainability Services at Accenture) focused on the proposed delay of the EU Deforestation Regulation (EUDR). The key points of the discussion covered the state of corporate readiness, speculation around possible regulatory simplifications, and strategic advice for companies during this extra time. The EUDR Delay and Corporate Readiness Deja Vu: The delay announcement, which followed a period of "radio silence" from the European Commission, felt like a repeat of events in 2024. Varied Preparedness: Corporate maturity regarding EUDR compliance is highly varied. "Lock and Loaded": Some large clients are fully ready, having invested in processes, due diligence, and are already voluntarily filing statements with the EU Traces system. "Half Ready": Many companies have designed procedures but haven't fully implemented or tested them. The delay is an opportunity for them to reinforce the robustness of their systems and perfect supplier due diligence. Unprepared: A significant number of companies were still "sitting on the fence" and would have been non-compliant without the delay. Supplier Impact: The delay brought a mix of frustration and relief; many suppliers immediately welcomed the extra time as they were not ready to provide the required deforestation-free data (polygons, geolocations). Speculation on Simplifications and Enforcement Potential Text Reopening: The panelists discussed the possibility of the EU Commission reopening the adopted text to include simplifications, though this is uncertain. "No-Risk" Classification: Stakeholders are advocating for a "no-risk" country classification that would remove due diligence requirements entirely for operators sourcing from those countries. Removal of Trader Responsibility: Another proposal is to remove the obligation for traders (who do not transform the product) to submit a due diligence statement. Enforcement Complexity: Mr. Mitik detailed the challenges in uniform enforcement and preventing circumvention: EU Traces Data Usage: The Commission is expected to use submitted geolocations to conduct automated checks against satellite imagery. This could lead to investigations, but the efficiency and consistency across all Member States are questionable. Mass Balance Evasion: Without strict data collection from all parties (including traders), it is difficult for authorities to perform mass balance calculations to catch suppliers who fraudulently declare the same deforestation-free land for multiple buyers whose total orders exceed the land's theoretical yield. Member State Disparity: While the Commission is working on capacity building, enforcement will initially be non-uniform, with some national competent authorities being much more prepared and rigorous than others. Strategic Advice for Companies Treat the Delay as an Opportunity: The additional year must be used actively; companies cannot afford to be in the same position in October 2026 as they are now. Shift from CSR to Proof-Based Compliance: Companies with pre-existing voluntary Corporate Social Responsibility (CSR) programs need to transition to a much more rigorous, proof-based system required by the EUDR. This means: Stop Sourcing from suppliers who cannot definitively corroborate the deforestation-free status of their commodities. Address the underlying issue of supply and demand driving illegal deforestation through public-private partnerships. Supplier Readiness and Contracts: Revisit Contractual Frameworks: This is the most critical immediate action. Companies need to introduce EUDR requirements into their sourcing agreements. Documented Access to Due Diligence: Buyers must secure documented access to their suppliers' due diligence systems and performance data, even if the supplier is unwilling to share the farmer's precise geolocations to prevent bypassing their business. They must verify that the supplier's system is functioning and that proof is available upon request. The panel concluded by reinforcing that the EUDR is here to stay, and businesses must continue their preparation to ensure they are fully compliant by December 2026.