My European Union (EU) buyer wants an audit or extra documents for the EU Deforestation Regulation (EUDR). Is that allowed?

Often yes, if the buyer is the operator. Article 11 lists measures an operator may take to reduce risk, including asking for additional information, data or documents and carrying out independent surveys or audits. Whether you must accept an audit depends on your contract.

What Article 11 lets an operator do

• Require additional information, data or documents.
• Carry out independent surveys or audits.
• Take other measures about the information requirements in Article 9.
• Support compliance by its suppliers, in particular smallholders, through capacity building and investments.

When a buyer reaches this step

The Commission says mitigation is needed unless the risk assessment finds no or only a negligible risk, and the measures must make the risk negligible. Under simplified due diligence for low risk countries (India is listed as low risk) the operator does not have to fulfil Articles 10 and 11, but if it obtains information pointing to a risk, it must fulfil all of them.

Our reading: a request for an audit usually means the buyer found something it could not close from your documents, such as a mixed lot, a plot near forest, or records that do not match.

What the buyer must have in place

• Every operator must have adequate and proportionate policies, controls and procedures to mitigate and manage the risks found, including model risk management practices, reporting, record-keeping, internal control and compliance management.
• For operators that are not micro, small or medium-sized enterprises (SMEs), that includes a compliance officer at management level and an independent audit function to check the internal policies, controls and procedures.
• Our reading: this is the buyer's own internal audit, not an audit of you. Ask which one is meant.
• Our reading: downstream operators and traders do not have to carry out due diligence, so a buyer in that role is not using Article 11 on you. Ask which role your buyer holds.

How to answer

• Ask what gap the request closes, then send the specific document, such as a land record for one plot, rather than a general folder.
• Agree who pays and who owns the audit report before the visit.
• Keep a copy of everything you send, since the buyer must keep its records for five years.

What Senseible does here

Senseible reads the HS code on each purchase invoice and keeps every invoice dated, so you can show your buyer what came in, from whom and when. Plot coordinates come from your growers and your buyer files the statement. We do not file statements or certify deforestation-free status.

• What an Indian supplier gives the EU importer for the statement
• India as a low risk country under EUDR
• Geolocation for Indian smallholder farms
• EUDR readiness: what applies to your goods

Sources: European Commission Green Forum, Understand due diligence under the EU Deforestation Regulation

Last reviewed 2026-11-05. Article 11 wording is as quoted on the Commission due diligence page. The page says there is no fixed format, so the request you get may differ.