The long-awaited EU Deforestation Regulation (EUDR) has been subject to numerous changes and delays since its initial introduction. The timeline for companies to comply with the legislation, which seeks to prevent the sourcing of EU products from deforested land, has recently been postponed yet again – now coming into effect on 30 December 2026 for large and medium-sized businesses, and 30 June 2027 for 'micro' or small enterprises. In this piece, Priscillia Moulin, co-founder and director of strategy at MosaiX and senior advisor at Earthqualizer Foundation and Inovasi Digital, explains why maintaining continuous compliance will be the critical challenge for companies.

The European Union Deforestation Regulation has rightly dominated strategic discussions throughout 2025. Large and medium-sized companies will likely be subject to enforcement from the end of next year. As such, companies are busy collecting geolocation data, implementing due diligence systems and preparing their first Due Diligence Statements (DDS).

However, a more pressing question looms: will that be enough to actually stay compliant?

Many operators mistakenly view EUDR compliance as a one-time data collection exercise – a static snapshot to be taken and submitted. This is a serious miscalculation.

The true challenge, and the greatest risk of major fines or market exclusion, lies not in getting compliant, but in the far more complex and crucial process of maintaining continuous compliance through ongoing monitoring and robust, on-the-ground remediation.

The illusion of static compliance

The core mandate of the EUDR is clear: companies must demonstrate that their in-scope products (including cocoa, coffee, soy, palm oil, wood, rubber and cattle) were not produced on land deforested after 31 December 2020. This requires full traceability down to the plot of land and submission of the DDS.

The initial steps – collecting coordinates and plugging them into a digital system - are the 'easy bit'. They demonstrate an intent to comply. However, a static database of supplier coordinates is only a point-in-time reference. The reality is that high-risk agricultural supply chains are dynamic. Deforestation is a continuous and evolving process driven by numerous local pressures (not least the unintended consequences of EUDR driving small holders to sell to unregulated markets).

Compliance under EUDR is a continuous monitoring obligation. Relying solely on historical data or sporadic checks will inevitably lead to a situation where a company is technically non-compliant without knowing it. The consequence is not just a regulatory slap on the wrist, but substantial fines (up to 4% of EU turnover), severe reputational damage and the potential exclusion of entire product lines from the European market. The UK, meanwhile looks likely to align its regulation alongside the EU, meaning potential double jeopardy for commodity importers.

What real-time alerts really mean

The true test of a company’s EUDR readiness is its Deforestation Alert Response Protocol.

Leading digital due diligence systems integrate satellite monitoring to continuously check supplier geolocation data against tree cover loss. When a potential deforestation event is detected on or near a sourced plot, an automatic alert is triggered. This alert is the moment of truth that separates compliance leaders from those who merely submitted their paperwork.

For an unprepared company, this alert exposes a fatal flaw: the chasm between the digital notification and the physical reality on the ground. A satellite alert, even a high-confidence one, is meaningless without a validated, on-the-ground procedure to determine two critical factors:

Attribution: Was the clearing done by the identified supplier for the EUDR commodity, a neighbouring farmer or an unrelated third party (e.g. illegal logging or land speculation)?

Legality and cause: Was the clearing for agricultural expansion of the relevant commodity or for a non-EUDR-related purpose (e.g. infrastructure development)?

Without established protocols and trusted local partnerships, a company cannot verify these facts quickly. This inability to act adds confusion, rather than clarity, with every single alert. This exposes the biggest flaw in systems like these – if you don’t know what’s happening, and you don’t have the resources to address it, you can’t mitigate risk.

The missing link

This issue moves the conversation beyond just data collection to the far more complex and crucial challenge of remediation. The majority of companies will be unprepared for this local complexity because they lack two essential components: trusted partnerships and standardised remediation processes.

The necessity of trusted local partnerships

The supply chain for high-risk commodities, such as palm oil, soy and cocoa, originates in complex jurisdictions with intricate land-use laws and varied socio-economic conditions. Effective remediation requires:

• Local language and cultural expertise: Needed to effectively and fairly engage smallholders, local mills and community leaders.

• Knowledge of local legality: A deep understanding of national land tenure laws, which are an explicit requirement of the EUDR’s legality criteria (covering land use rights, labour rights, and Free, Prior and Informed Consent (FPIC)).

• Verification field teams: Teams on the ground who can quickly and accurately visit the coordinates, verify the nature of the clearing and document the evidence to auditable standards.

Digital compliance solutions alone cannot solve problems rooted in human and legal geography. An integrated approach must connect the satellite data stream directly to regional expertise – this integration of technology and local knowledge is the only way you can respond in the right way.

Standardised remediation and mitigation

If deforestation is verified and attributed to a supplier, the response must be immediate and transparent. A failure of due diligence is not just a failure to detect risk, but a failure to mitigate it and make things right.

Does the company have:

• A clear grievance mechanism?

• Defined restoration or corrective action plans for non-compliant areas and suppliers?

• A plan for providing capacity-building and support to help smallholders and suppliers prevent future non-compliance?

These are complex questions, but simply cutting and running from a non-compliant supplier, a practice that often merely shifts the deforestation problem to other non-EU markets, is unacceptable under the spirit of the EUDR. Competent authorities expect to see documented evidence of due diligence, which includes an attempt at mitigation and remediation before considering market exclusion.

The importance of integrated systems

Compliance doesn’t mean simply having a data portal and some satellite monitoring – it's about having a system that converts data into audited, defensible action. The threat is not just a fine, but a total loss of access to the European market. Getting the initial due diligence submission right is essential, but it’s only the start of the process.

The next, and most defining, challenge is building the resilient infrastructure that allows an organisation to confidently, quickly and effectively address any non-compliance. Getting compliant is a necessary first step; staying compliant through verifiable, on-the-ground remediation is the next challenge and one businesses must be ready for.