regulations

Battery Due Diligence: New Deadline 18 August 2027 (Reg. 2025/1561)

Reg. (EU) 2025/1561 delayed EU battery due diligence by two years to 18 August 2027. What changed, the new timeline, and how to prepare now.

4/17/2026 · 7 min read · InfoDPP

Update, 6 September 2026: the 26 July 2026 deadline for the Commission’s battery due diligence guidelines has passed. As of 6 September 2026 we found no published guidelines on the Commission’s battery pages or in the Official Journal. The 18 August 2027 application date of Article 48 is unchanged; companies should keep building their due diligence policy on the OECD guidance the regulation refers to rather than wait for the guidelines.

What Changed in One Paragraph

Regulation (EU) 2025/1561, adopted by the European Parliament and the Council on 18 July 2025 and published in the Official Journal on 30 July 2025, amends Article 48(1) of the Battery Regulation (EU) 2023/1542. The amendment postpones the battery supply-chain due diligence obligations by two years, from 18 August 2025 to 18 August 2027. The legal deadline for the Commission’s battery guidelines remains 26 July 2026. That date matched the CSDDD guidance timetable when the amendment was adopted, but Directive (EU) 2026/470 subsequently moved the main CSDDD guidance deadline to 26 July 2027.

The amendment changes two dates: the start of due diligence and the deadline for Commission guidelines, previously 18 February 2025. It does not change the battery-passport date of 18 February 2027 under Article 77.

Which Obligations Actually Moved

Article 48 of the Battery Regulation requires economic operators that place batteries on the Union market to operate a due diligence policy covering supply-chain risks for four critical raw materials: cobalt, lithium, natural graphite, and nickel. Article 47 exempts operators with net turnover below €40 million in the financial year preceding the last financial year, provided their group’s consolidated turnover does not exceed €40 million. It also excludes the specified second-life operations on batteries already placed on the market or put into service. For operators within scope, the policy must include:

a management system with policies and procedures
supply-chain risk identification, assessment, mitigation and monitoring
third-party verification by a notified body
annual public reporting on due diligence steps

The obligations apply from 18 August 2027. Article 52(3) requires the public report to be reviewed and published annually. It does not establish 18 August 2028 as a separate first-report deadline. A three-year cycle is a proposed change, not the rule currently in force.

Why the Delay

The recitals of Regulation (EU) 2025/1561, together with Council and Parliament communications, cite four reasons for the postponement:

Geopolitical and raw-material shifts. Companies need more time to analyse and adjust their supply chains for cobalt, lithium, graphite and nickel in a volatile sourcing environment.
Notified body designation was slower than expected. Without a sufficient network of third-party verifiers, economic operators could not realistically meet verification obligations on the original date.
Due diligence schemes need time to mature. Recognition of sector-specific schemes by the Commission takes time, and companies need a clear menu of options before committing to one.
Alignment with CSDDD was the 2025 rationale. Harmonisation was intended to avoid duplicate reporting, but the later CSDDD amendment separated the publication deadlines: battery guidance remains dated 26 July 2026, while the main CSDDD guidance is due by 26 July 2027.

What Omnibus IV Proposes, but Has Not Yet Made Law

Separately from Regulation (EU) 2025/1561 (which is adopted and in force), the Commission tabled COM(2025) 501 on 21 May 2025 as part of the Omnibus IV small mid-cap simplification package. This is a proposal, not adopted law. It is currently in the ordinary legislative procedure: the Council adopted its negotiating position on 24 September 2025, the European Parliament adopted its report on 25 February 2026, and interinstitutional negotiations opened on 11 March 2026.

COM(2025) 501 would amend Regulation (EU) 2023/1542 (along with several other acts, including GDPR and F-gas). Within the battery file, the Commission proposal and subsequent parliamentary and negotiating positions address three distinct matters:

in the Commission text itself, extend the Article 47 exemption to operators below €150 million net turnover (and groups below the same consolidated threshold)
in the Commission text itself, change the Article 52 public due diligence policy review/reporting cycle from annual to every three years
in Parliament’s report and the wider Omnibus framing, describe SMCs more broadly as firms that are not micro, small or medium-sized, with fewer than 1,000 employees and annual turnover up to €200 million or a balance-sheet total up to €172 million

Until the final text is adopted and published in the Official Journal, none of these items are binding. Companies that fall inside the current scope of Article 48 should not plan compliance on the assumption that COM(2025) 501 will be adopted unchanged.

What This Means for DPP Planning

The battery passport (Article 77) and battery due diligence (Article 48) were always two separate compliance streams. Regulation (EU) 2025/1561 widens the gap between them:

Obligation	Legal basis	Application date
Battery passport	Reg. 2023/1542, Art. 77	18 February 2027
Supply-chain due diligence	Reg. 2023/1542, Art. 48 (as amended)	18 August 2027
Commission due diligence guidelines	Reg. 2023/1542, Art. 48 (as amended)	by 26 July 2026
Public due diligence reporting	Reg. 2023/1542, Art. 52(3)	Annual review and publication; obligations apply from 18 August 2027

Annex XIII includes a data point for the public due diligence report. From 18 February 2027 until 18 August 2027, the passport will be live before the underlying due diligence obligation applies. That does not make the data point mandatory during the gap:

The schema may prepare the field early, but its value is “not applicable”. It must not be presented as required passport content before the relevant obligation applies to that battery category.
Evidence work should not stop. Supply-chain mapping, risk assessment, and verification preparations still need to be ready for 18 August 2027, even if some companies choose to stagger the formal reporting step.

July 2026 update: DG GROW’s 7 July webinar clarified the timing. Carbon-footprint, recycled-content and due-diligence information is included only in passports for batteries placed on the market after the corresponding requirement starts to apply to that category. Until then the data point is not applicable, even if the system is technically ready to store it.

What To Do in 2026

Treat the passport (Art. 77) and due diligence (Art. 48) as parallel projects, not as one bundle. Different teams, different evidence, different verification paths.
Verify publication of the due diligence guidelines whose legal deadline is 26 July 2026. The statutory date is not itself proof that the document has been published; once available, the guidelines will define management systems, risk assessments and reporting structures.
Watch COM(2025) 501 without planning on it. If the final text carries forward the €150 million exemption threshold and SMC mitigations, it may change who is in scope and how frequently reports are due, but scope planning today should be based on the regime currently in force.

Official Sources

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