regulations

Battery Due Diligence Delayed to 18 August 2027 (Reg. 2025/1561)

Reg. (EU) 2025/1561 pushed battery due diligence from 18 Aug 2025 to 18 Aug 2027. What changed, why, and what COM(2025) 501 proposes next.

4/17/2026 · 7 min read · InfoDPP

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 Commission’s due diligence guidelines — originally due 18 February 2025 — are now expected by 26 July 2026, aligned with the guidance timeline under the CSDDD (Directive (EU) 2024/1760).

This is the only substantive change the amendment introduces. It does not change the battery passport timeline under Article 77, which still applies from 18 February 2027.

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. Concretely, 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

Under the original timetable, all of these elements had to be operational by 18 August 2025. With Regulation (EU) 2025/1561 in force, the deadline for all elements shifts to 18 August 2027. First public due diligence reporting therefore becomes due later as well: the regulation structure points to a first report roughly a year after application (18 August 2028), with further reports at least every three years.

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. Harmonising battery due diligence guidance with the corporate sustainability due diligence framework avoids duplicative reporting for operators in scope of both regimes.

What Omnibus IV Proposes — Not Yet 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 text itself and the later parliamentary/negotiating positions point to three distinct items:

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 land 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
First public due diligence report	Reg. 2023/1542, Art. 52	~18 August 2028

Annex XIII includes fields that reference supply-chain due diligence information. From 18 February 2027 until 18 August 2027, the passport will be live before due diligence obligations are legally enforceable. In practice that means two things:

The data model still needs those fields. Passport systems should carry the due diligence sections even in the six-month gap, because they will be required shortly after passport go-live.
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.

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.
Track the due diligence guidelines expected by 26 July 2026. They will define the concrete content of 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

Building a battery passport workflow that keeps Annex XIII, due diligence evidence and BMS data in one auditable record? Start free on OriginPass.eu and pilot the data model before the 2027 deadlines hit.

← Back to Blog