December 2025 has brought significant regulatory shifts, moving from policy debate to concrete implementation. For compliance teams, the focus must now shift to operational readiness. This briefing outlines the critical changes to CSRD, EUDR, and product compliance, providing the clarity you need to adjust your strategy for 2026.
This month confirmed new timelines and narrower scopes for key regulations, while simultaneously increasing the pressure for robust data and enforcement readiness. Below is a summary of the key developments and what they mean for your business.
In This Briefing
Executive Summary: Key Changes & Immediate Actions
December marked a pivot from discussion to action. While some regulations were simplified, the overall ambition for data quality and implementation is rising.
Key Regulatory Changes
- CSRD & CSDDD Scope Reduced: The new thresholds (1,000+ employees / €450m turnover) remove many mid-sized companies but increase the need for consistency for those remaining in scope.
- EUDR Delayed & Simplified: The application date is now 30 December 2026. This extension should be used to stabilise data systems, not pause activity.
- Product Compliance Tightens: Substance restrictions (PFAS, RoHS) and product safety rules (GPSR) are expanding, demanding end-to-end traceability.
- Green Claims Scrutiny: Enforcement risk is rising faster than new legislation. Authorities are linking consumer claims to CSRD reports, making data consistency a primary risk.
Immediate Actions for Compliance Teams
- Re-evaluate Scope: Confirm if your company meets the new CSRD/CSDDD thresholds.
- Reset EUDR Timelines: Update your project plan for the December 2026 deadline.
- Audit Claims: Ensure every public environmental claim is backed by verifiable evidence.
- Integrate Data: Move away from siloed data collection for compliance, supply chain, and reporting.
1. Disclosure: Reporting Scope Narrows, but Expectations Rise
The European Parliament has confirmed plans to simplify sustainability reporting, most notably by reducing the number of companies in scope for both the CSRD and CSDDD.
While this reduces the burden for many, expectations for those still covered are higher. The focus is on quality, not quantity, with sustainability data needing the same level of reliability as financial reporting.
- New Thresholds: The rules are set to apply to companies with 1,000+ employees and a net turnover above €450 million.
- Action: Immediately assess your company’s status against these new thresholds to determine your reporting obligations.
2. Due Diligence: More Time, but No Exemption
This month brought critical clarity for supply chain due diligence, led by the official delay of the EU Deforestation Regulation (EUDR).
- EUDR Application Postponed: The new application date is 30 December 2026.
- Core Obligations Remain: The fundamental requirements for traceability, risk assessment, and data availability are unchanged. The extension provides more time for implementation, not an exemption from the rules.
- Action: Use the extra year to improve the quality of your traceability data and supplier engagement models.
3. Product Compliance: Requirements Tighten as Simplification Focuses on Process
While “simplification” is a popular theme, the substance of EU product compliance continues to expand in scope and depth.
- Chemicals & Substances: Regulatory pressure on PFAS continues to accelerate, while RoHS exemptions evolve, requiring continuous bill-of-materials tracking.
- Product Safety: New guidance on the General Product Safety Regulation (GPSR) reinforces expectations for risk assessment and traceability.
- Action: Assume substance restrictions will continue to tighten and proactively design out high-risk materials from future products.
4. Consumer Information: Enforcement Risk Outpaces New Laws
Consumer-facing claims and labelling have moved to the frontline of regulatory risk. The focus has shifted from creating new rules to rigorously enforcing existing ones.
- Green Claims Scrutiny: Every environmental claim must be substantiated and verifiable. Authorities are linking claims to mandatory disclosures like CSRD reports.
- Data Consistency is Key: Inconsistent narratives across labels, websites, and annual reports are a material enforcement risk.
- Action: Audit your consumer-facing claims against your underlying product and supply chain data. If you cannot prove it, do not say it.
5. Energy & Environment: Long-Term Targets Hold Firm
The EU is not backing away from its core climate and environmental objectives. The long-term direction remains unchanged.
- 2040 Climate Target Confirmed: The EU will aim to reduce net greenhouse gas emissions by 90%, anchoring long-term transition expectations.
- CBAM Clarified: Recent adjustments are designed to manage competitiveness, not retreat from the mechanism. Obligations for importers on data collection and reporting remain fully in place.
- Action: Use the 2040 target to inform your transition planning. Integrate CBAM data requirements into core procurement and customs processes now.
How Jordisk Can Help
Navigating this evolving landscape requires strategic action and expert capacity. At Jordisk, we translate complex regulations into clear, actionable strategies that protect your business.
Our expertise can support your team in key areas:
- Strategic Impact and Gap Analysis: Determine exactly how regulatory changes affect your organisation.
- Operational Integration and Readiness: Build coherent policies, processes and systems to support multiple regulatory obligations, from CBAM to green claims.
- Supply Chain Due Diligence: Strengthen your traceability programmes and supplier engagement to meet rising expectations.
- Claims Substantiation and Risk Management: Audit your environmental claims to ensure you stay ahead of enforcement risks.
Whether you need targeted advice or broader support, our team provides the expert capacity to help you move from reactive policy tracking to resilient compliance.
