can I authorise a service provider to submit my due diligence statement on my behalf

Appointing a service provider can

Yes, you can: the deforestation regulation permits an operator to engage a third party to submit the due diligence statement on its behalf to the EU information system. However, the legal responsibility for the content of the statement and for the underlying risk assessment remains with the operator itself, even if another party technically carries out the submission. Outsourcing the submission therefore does not change who is accountable to the competent authority.

In practice, this means that a service provider must have access to the operator's account in the EU information system, or there must be another way to act on someone's behalf within that system. How that access is precisely arranged and what precautions are involved is a practical question that is separate from legal responsibility. For anyone wanting to know more about this, particularly regarding the question how a login key can be safely shared with a service provider, you will find the practical side of this matter. For the content of what is actually submitted, it remains useful to know what data must be included in a due diligence statement, even when someone else presses the button.

Where this follows from: the EU information system and the regulation

Regulation (EU) 2023/1115 places the obligation to submit a due diligence statement with the operator or trader, without excluding the possibility that the technical act of submission is performed by an appointed third party; the EU information system for the deforestation regulation (the register) is designed to process such submissions, and the European Commission describes how this system operates in the documentation on the implementation of the deforestation regulation. Anyone wishing to review the precise demarcation between technical submission and legal responsibility will find the full text on EUR-Lex.