Breaking down the double materiality assessment: what are IROs? (Updated June 2025)
Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
- New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
- Simplified DDS: One-time declarations for small and micro primary producers
- Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
- New DDS requirement: Estimated annual quantity of regulated products must be included
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
If your business is planning to report on the Corporate Sustainability Reporting Directive (CSRD), whether as a direct filer or a group, understanding key concepts like the double materiality assessment and how to identify impacts, risks, and opportunities (IROs) is essential.
In this article, we'll break down IROs and provide everything you need to know about their importance and how to include them in your CSRD reporting process.
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