EUDR and CSRD: how the reporting obligations overlap

If you are a medium or large EUDR operator, you already have to publish an annual public report on your due diligence system under Article 12(3) of Regulation (EU) 2023/1115 — and if you also report under the Corporate Sustainability Reporting Directive (CSRD), you do not have to write two documents. The regulation lets you fold the EUDR content straight into your CSRD sustainability statement instead of filing a separate notice. The overlap was built into the law on purpose; the practical complication is that a 2026 reform shrank CSRD's scope so hard that far fewer companies now have both obligations to combine.

Who actually has to report under each regime

EUDR's Article 12(3) public reporting duty falls on operators that are not SMEs — in the regulation's own size test, that means medium and large operators placing relevant products on the EU market for the first time, not micro or small ones. It does not apply to traders, and it does not apply to downstream operators and traders, who have a lighter registration duty instead of a reporting one.

CSRD used to catch roughly the same population, because its original thresholds (more than 250 employees, or more than €50 million turnover, or more than €25 million balance sheet total — exceed two of three) lined up closely with the EUDR "large" band. That changed with the Omnibus I simplification directive, Directive (EU) 2026/470, published in the Official Journal on 26 February 2026 and in force from 18 March 2026. It rewrote CSRD's scope to a single, much higher bar: more than 1,000 employees and more than €450 million net turnover. The Commission's own estimate is that this cuts the number of companies in scope from roughly 50,000 to around 5,000 across the EU.

	EUDR Article 12(3) report	CSRD sustainability statement (post-Omnibus)
Who	Medium and large operators (primary placers)	More than 1,000 employees and more than €450m net turnover
Legal basis	Regulation (EU) 2023/1115, as amended by (EU) 2025/2650	Directive 2013/34/EU, as amended by Directive (EU) 2022/2464 and Directive (EU) 2026/470
Covers	Deforestation due diligence only, for in-scope commodities	All material sustainability topics, double-materiality assessed
Frequency	At least annually	Annually, as part of the management report

The result: a medium-sized EUDR operator — say, 150 staff and €30 million turnover — has had an Article 12(3) report obligation since the regulation first applied to them, but almost certainly falls well short of CSRD's new 1,000-employee, €450 million threshold and has no CSRD report to fold it into. The genuine overlap is now concentrated at the top of the market: large multinational operators and traders who clear both bars. For everyone else, understanding which EUDR deadline and size band applies to you matters more than CSRD ever will.

What the EUDR report has to contain

Article 12(4) sets out the content, whether you publish it as a standalone document or embed it in something else. It has to include:

• A summary of the products and quantities assessed, and the countries of production.
• The conclusions of your risk assessments, with the mitigation measures you took as a result.
• The evidence and criteria you used to reach those conclusions.
• Where relevant, a description of any consultation carried out with indigenous peoples, local communities or civil society organisations affected by your supply chain.

None of this is a substitute for the due diligence statement you file in TRACES against individual consignments. Submitting a due diligence statement in TRACES is a per-shipment, pre-market-access obligation; the Article 12 report is a once-a-year, retrospective account of the whole due diligence system. You need both if you are a non-SME operator — the report does not replace the statement, and the statement does not replace the report.

How the two reports actually combine

Article 12(3) contains the specific permission that makes combination possible: operators who are also subject to other EU legislation requiring value-chain due diligence or sustainability reporting may satisfy their EUDR reporting duty by including the required Article 12(4) information in the report they already file under that other legislation. CSRD, via the European Sustainability Reporting Standards (ESRS), is the obvious fit, because a sustainability statement already has a dedicated section for exactly this kind of disclosure.

In practice, that means:

1. You still have to produce all four categories of Article 12(4) information — combining reports does not reduce what you must disclose.
2. You place that information inside your CSRD sustainability statement, typically under the biodiversity and ecosystems standard, rather than publishing a second standalone EUDR report.
3. The sustainability statement's own publication and assurance timetable becomes your Article 12(3) timetable for that information. You do not get to publish it later just because the statement follows a different internal production schedule.
4. If your CSRD reporting obligation ever lapses — the Omnibus narrowing moved genuine companies out of scope between financial years 2025 and 2026, with a transition exemption some member states applied — your standalone Article 12(3) duty does not lapse with it. You revert to publishing your own report.

Where biodiversity reporting standard ESRS E4 fits

If you do report under CSRD, the natural home for your EUDR content is ESRS E4, the standard covering biodiversity and ecosystems, which explicitly addresses land use change and deforestation impacts and dependencies. It is not, however, an automatic requirement for every CSRD reporter: ESRS operates on double materiality, so you only have to report against E4's detailed disclosure requirements if your own materiality assessment concludes that biodiversity and ecosystem impacts are material to your business. A company placing deforestation-risk commodities on the market is a strong candidate for E4 being material almost by definition, but the assessment itself is not optional even where the conclusion looks obvious on paper.

ESRS itself was simplified alongside the scope change. The Commission adopted a delegated act revising the standards on 3 July 2026, cutting the total number of mandatory and voluntary data points by more than two-thirds compared with the original 2023 set. The revised standards apply mandatorily to financial years beginning on or after 1 January 2027, with early adoption allowed for financial year 2026. If you are combining EUDR and CSRD reporting for the first time, check which version of ESRS your financial year falls under, because the structure of the biodiversity disclosures — and the reporting templates that line up with Article 12(4) — differ between the original and the simplified sets.

What the overlap does not cover

Three things people conflate with this overlap, and should not:

• CSDDD is a different law. The Corporate Sustainability Due Diligence Directive covers human rights and environmental due diligence across a company's whole value chain, not just deforestation-risk commodities, and it too was narrowed by the Omnibus package. A company can have CSDDD obligations without EUDR ones, or EUDR obligations without CSDDD ones. Do not assume meeting one satisfies the other; they overlap in spirit but not in legal text.
• Reporting is not due diligence. Folding your Article 12(4) summary into a CSRD statement changes where you publish the conclusions, not what you have to do to reach them. You still need country benchmarking, geolocation data down to plot level, and a documented risk assessment before you have anything true to report.
• Falling out of CSRD scope does not remove EUDR exposure. A business that drops below the new 1,000-employee threshold loses its CSRD sustainability statement but keeps every EUDR obligation that its size band and product mix create, including the standalone Article 12(3) report if it is still a medium or large operator. The two scope tests are entirely independent; nothing in what changed under Regulation (EU) 2025/2650 links them.

A worked example

A UK-headquartered edible oils trader places palm oil and palm derivatives on the EU market as the first operator in the chain. It employs 400 people and turns over €180 million.

• EUDR: large operator, non-SME. Article 12(3) report required annually. Deadline for the operation as a whole: 30 December 2026.
• CSRD: below the post-Omnibus threshold on both employee count and turnover. No sustainability statement obligation.

Outcome: this business cannot combine its reports, because it has no CSRD statement to combine into. It publishes a standalone Article 12(3) report containing the summary, risk assessment conclusions, evidence and any community consultation record. If its group turnover or headcount later pushes it over 1,000 staff and €450 million — through growth or a merger — it gains a CSRD obligation and can then migrate the same content into its sustainability statement, provided the group-level consolidation that applies to size banding generally puts it over the EUDR non-SME line too.

Getting this right before your deadline

Work out which of the two size tests you actually meet — not which one your compliance team assumes you meet — before deciding how to structure next year's reporting. A business past its EUDR date with no CSRD obligation still has to produce a standalone Article 12(3) report if it is a non-SME operator; skipping it because "we report on sustainability elsewhere" is not a defence if that other report does not exist or does not cover the Article 12(4) content.

Check what your business actually has to report under the EUDR and get a plan that separates what you must publish from what you can combine.