how does the EU verify whether my plots were deforested after the cut-off date

Satellite imagery and geolocation provide the foundation

The EU verifies this primarily by linking the geolocation of a parcel to satellite imagery and maps from before and after the cut-off date of 31 December 2020. Once you submit the coordinates of a parcel, a competent authority can use available monitoring tools to check whether tree cover has disappeared at that location after that date. This is precisely why the quality of the geolocation data you submit yourself carries such weight: inaccurate or incomplete coordinates make that comparison impossible or unreliable, which increases the operator's own risk.

For SMEs, this means above all that maintaining their own records is the starting point of any inspection, not the endpoint. The authority does not blindly trust what has been submitted, but uses the specified points or polygons as a basis to verify independently. How parcels from multiple countries of origin, or a polygon versus a single point, are handled in detail varies by situation — more on this is available at when a point suffices and when a polygon is needed and at compiling geolocation for mixed batches. What an operator does not do itself is declare that a parcel is deforestation-free based on its own assessment of those images; that assessment rests with the due diligence assessment required by the regulation and, where applicable, with the competent authority.

What this is based on

This procedure follows from the definition of deforestation-free products and the cut-off date in Regulation (EU) 2023/1115, combined with the geolocation requirements for parcels that the due diligence declaration must contain. The European Commission describes on its page on implementing the regulation that monitoring and satellite data are part of the oversight system, and that submitted declarations are accessible via the EU information system for competent authorities. What geolocation data is precisely needed from your own parcels is described on the page on submitting geolocation data for your parcels.