Yes, the entry date of the Regulation has been adjusted. The regulation was originally due to enter into force at the end of 2024, but has been postponed by approximately one year through an amendment. For large and medium-sized enterprises, the end of December 2025 is now the moment when obligations begin; for micro and small enterprises, this is half a year later, mid-2026. This distinction is now enshrined in the amended regulation itself, no longer in a proposal or announcement.
What changes for most small and medium-sized enterprises, therefore, is not the content of the obligation but the moment when it comes into effect. The question of which date applies to you depends on your company size and the role you have in the supply chain: operator or trader. Anyone who has not yet clarified this can have it calculated in a few questions.
What exactly has changed
The amendment concerns the dates, not the obligations themselves. The due diligence obligation, the geolocation data, the record-keeping requirement and the submission to the EU information system remain structurally unchanged. What has been adjusted is the start date: enterprises were given an extra year to prepare, with a phased start based on company size. This means that a date you read somewhere last year may no longer be correct — not because the source was wrong, but because the regulation itself has been revised.
This type of adjustment is common in practice with major European regulatory implementation dates. It is therefore advisable, if in doubt, not to rely on a date from an article from a year ago, but on the current text or on a source that is kept up to date. In the knowledge base the applicable date for each situation is indicated by subject, along with where to find it in the official text.
Which date applies to whom
The phased start does not mean that everyone received the same extra time. Large and medium-sized operators and traders fall under the earlier date; micro and small enterprises under the later one. In addition, the risk classification of the country of origin plays a role in the scope of the obligations, but not in the start date itself — this is a different distinction from the date on which the regulation begins to apply to you.
Because company size, role and product stream together determine which date applies to you, a general date from a news article is never a guarantee that it also applies to your situation. Competent authorities assess compliance based on the concrete situation of the enterprise, not on what has been written generally about the sector.
Why postponement is no reason to wait
The postponement has been a relief for many enterprises, but it does not change the amount of work needed to be ready in time. Suppliers ask for origin data, collecting and validating geolocation data, and building a file per product stream takes time, especially if you work with multiple countries of origin. Enterprises that started last year used the extra time to do this calmly rather than in the final months.
The possibility that more changes will occur this year cannot be ruled out and cannot be predicted either. What is certain, however, is that the core of the regulation — what you must record and why — has remained unchanged for some time. It is therefore worthwhile to start structuring what you already know now, even if the exact date for your category still lies a few months ahead.
What has remained unchanged
The obligation to be able to demonstrate that a product is traceable to the plot level has not been amended. Nor have the document retention requirements or the manner in which a due diligence statement is submitted to the EU information system been affected by the date change. Anyone wondering what that process looks like in practice will find an overview on the page where the information comes from.
How to check this for your own situation
Because the combination of your role, company size, and product determines which date applies to you, the safest way to verify this is always to consult the current official text, or in case of doubt to ask the competent supervisory authority or a lawyer about your specific situation. General reporting, including this article, describes the regulation in broad strokes and is not a substitute for it.
If you want to quickly find out which date appears to apply to your company and why, you can take the free role check or go through the frequently asked questions on this overview page. Both provide an immediate concrete indication, without requiring you to have an account.