Large undertakings & EUDR

Some of the obligations set out in the EUDR depend on the size of the undertaking. The obligations of operators are the same regardless of company size, with the exception of the obligation for large undertakings to issue annual public reports on their due diligence system. Large undertakings that act as downstream operators or traders are required to register in the EUDR Information System.

In addition, large undertakings must immediately inform the competent authorities if, before placing products on the market, making them available on the market or exporting them, they receive information indicating that a product does not comply with the requirements of the EUDR. If there are substantiated concerns, large undertakings must also verify, before placing products on the market, making them available on the market or exporting them, that due diligence has been carried out, and that no risk has been identified or that only a negligible risk has been identified. See Article 5(6) of the EUDR.

A company is considered a large undertaking if it exceeds at least two of the following criteria on the balance sheet date:

• balance sheet total exceeds EUR 25,000,000
• net turnover exceeds EUR 50,000,000
• average number of employees during the financial year exceeds 250

Please note: Article 3 of Directive 2013/34/EU has been amended by Commission Delegated Directive (EU) 2023/2775, which revises the size criteria for companies. The Act amending Chapters 1 and 7 of the Accounting Act (605/2024) entered into force on 15 November 2024.

See also the Commission’s FAQ, Implementation of the EU Deforestation Regulation, Version 4, Question 3.10, and the Accounting Act, Chapter 1, sections 4a–4c.

Please note: Previously, large undertakings engaging in trading or further processing had the role of operator in accordance with the EUDR. Under the amending Regulation (EU) 2025/2650, such companies are no longer considered operators; instead, their obligations are aligned with those of other downstream operators or traders, with the exception of the specific obligations for large undertakings described above on this page.

Annual reporting obligation

Large undertakings that are operators have an annual obligation to issue public reports on their due diligence (DD) system and measures.

• The reporting must be as comprehensive as possible and must also be published online. It must cover the company’s DD system, including the measures taken to fulfil the obligations laid down in Article 8.
• The reports must include the following information about the relevant commodities and products:
  • a summary of the information referred to in points (a), (b) and (c) of Article 9(1);
  • risk assessment conclusions, the measures taken, and a description of the information and evidence obtained and used to assess risks;
  • where applicable, a description of the process of consultation of indigenous peoples, local communities and other customary tenure rights holders or of the civil society organisations that are present in the area of production of the relevant commodities and relevant products.
• For more details about the reporting obligation, see Article 12(3) of the EUDR.

Risk mitigation measures

Large undertakings that are operators must also mitigate risks by arranging internal controls and an independent audit function for their activities. Large undertakings must reduce risks through adequate and proportionate policies, controls and procedures. These must include:

• model risk management practices, reporting, record-keeping, internal controls and compliance management, including the appointment of a compliance officer at management level;
• an independent audit function to check the internal policies, controls and procedures.
• For further details, see Article 11(2) of the EUDR.