The EUDR timeline: every deadline, by company size

Which date applies to you?

Enter your figures. You qualify as micro or small if you are within the limits of at least two of the three criteria, which is not the same as needing to be under the headcount ceiling.

• Employees
• Annual turnover (€m)
• Balance sheet total (€m)

Nothing is sent anywhere. This runs entirely in your browser.

The two dates

Both were set by Regulation (EU) 2025/2650, adopted in December 2025. The May 2026 simplification package left them untouched.

How company size is actually determined

The decisive date is 31 December 2024, not today. For the deferred application date, what counts is whether you were a micro or small undertaking by 31 December 2024, judged against the thresholds in force on that day. A company that has grown past the thresholds since then keeps the later deadline. Growth in 2025 or 2026 does not pull you into December 2026.

The EUDR borrows the definitions from EU accounting law rather than inventing its own. A company is micro or small if, on its balance sheet date, it does not exceed the limits of at least two of these three criteria:

• Headcount: 50 employees
• Net turnover: €10 million
• Balance sheet total: €5 million

Two practical consequences follow, and both catch people out.

National thresholds do not apply

Member States may raise the small-undertaking thresholds in their own transposition of the Accounting Directive, and several have. Those national figures are not the ones to use. The 5th FAQ is explicit that national size thresholds are not relevant for size determination under the EUDR, because the Regulation is based on the thresholds in the Accounting Directive itself. Use 50 employees, 10 million euro net turnover and 5 million euro balance sheet total wherever you are established.

Mixed business, and the carve-out that applies to producers

There is a carve-out, and it is narrower than it first sounds: it attaches to the micro or small primary operator route, not to size classification generally. Where only part of a business relates to the relevant commodities and products, only that part counts towards the thresholds. Turnover, employees and balance sheet items that logically belong to the other activities are left out, and staff working across both are counted pro rata.

The 5th FAQ works an example: a company earning seventy per cent of its turnover from processing and marketing wood products and thirty per cent from transporting metal pieces counts only the seventy per cent. The price of the carve-out is evidence. On a check you have to produce business records, revenue structure or cost accounting that allocate the figures transparently across segments.

It is assessed per legal entity, not per group

The 5th FAQ settles this. The balance sheet, net turnover and number of employees of the individual legal entity, not of the group as a whole, is decisive. Subsidiaries of a group refer to Directive 2013/34/EU like any other legal entity, and each entity that meets the definition of operator, non-SME downstream operator or non-SME trader creates its own account in the information system.

So the three-person trading arm of a multinational is assessed on its own three-person figures. That cuts the other way too: within a group, every legal entity is considered individually, which means the first downstream operator or trader in a chain can be another member of the same group.

The status has to persist

Size applies per financial year, judged on the last financial year for which the figures are available. A change of classification happens only where you exceed, or cease to exceed, two of the three thresholds for two consecutive financial years. The 5th FAQ states this directly for the EUDR, and applies it both to moving between SME and non-SME and to a producer moving in or out of the micro or small primary operator route. One unusual year moves nothing, in either direction.

If you are close to the line, plan for December 2026. The cost of preparing eighteen months early is some wasted effort. The cost of concluding you were small and discovering in January 2027 that you were not is that every consignment you placed was placed unlawfully. The asymmetry is severe enough that borderline companies should simply take the earlier date.

What happens in the gap

Between 30 December 2026 and 30 June 2027 the market operates under two regimes at once. That creates three specific problems.

• Your large customers will demand data before you are obliged to provide it. A small supplier to a large roaster or retailer is not bound until June 2027, but their customer is bound in December 2026, and cannot file without upstream geolocation. In practice the commercial deadline arrives eighteen months before the legal one.
• Small operators can still be traders in a bound chain. If you make products available to someone who places them on the market, your data becomes their compliance problem, and they will make it yours contractually.
• Mixed consignments need care. A batch combining material from bound and unbound operators does not get the later date. The obligation follows the operator placing it on the market.

Working backwards from December 2026

Five months is enough time, but only if the sequence is right. Geolocation is the long pole. It depends on other people, in other countries, often during a specific window in the season.

1. 1.Now: confirm role and size, re-check product scope against the amended Annex I, and establish country classifications.
2. 2.Next harvest cycle: collect plot geolocation. If you miss the window, you wait a year. There is no way to buy this back later.
3. 3.Two months out: run a complete dry filing on a real consignment. Every gap surfaces here.
4. 4.One month out: brief suppliers on what they must send with each delivery, and get it into contracts.

Related

• Is the EUDR delayed?, the full history and why a third postponement is not coming
• Who has to comply, operator, trader, and what each role owes
• Country benchmarking, which of your chains qualify for simplified due diligence