AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Under the EU deforestation regulation (EUDR, Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650), large and medium operators that first place regulated products such as cocoa on the EU market must submit a due diligence statement from 30 December 2026. Micro and small operators follow on 30 June 2027 for most products, and downstream operators and traders no longer file their own statement but must keep the reference number of the first one.
Nigeria exports cocoa beans, butter and powder, and Italian chocolate makers, roasters and traders buy them. The EUDR’s start date has been pushed back and its obligations simplified. This guide sets out what the latest amendment says and what an Italian importer should already be doing.
The dates as they now stand
The European Commission’s Access2Markets service, in a news item of 28 January 2026, describes the amending Regulation (EU) 2025/2650, which changes Regulation (EU) 2023/1115:
| Who | Applies from |
|---|---|
| Large and medium-sized operators | 30 December 2026 |
| Micro and small enterprises, products also in the old EU Timber Regulation annex | 30 December 2026 |
| Micro and small enterprises, other EUDR products | 30 June 2027 |
| Downstream operators and traders, all sizes | 30 December 2026 |
Confectionery News reported the delay on 17 December 2025 in similar terms and added that the Commission was to review the regulation by 30 April 2026, a review that could bring further simplification. The outcome of that review is not covered here; check the Commission’s EUDR pages before relying on these dates.
Is your cocoa product in scope?
The EUDR applies to the commodities and products listed by customs code in its annex. Cocoa is commonly cited as one of the regulated commodities, but whether a given product is covered depends on its code, so beans, butter, powder and finished chocolate may not all be treated alike. Check your CN code against the annex with your customs broker before assuming you are in or out.
Who does what
The operator who first places the product on the EU market
If your Italian business imports the cocoa and is the first to put it on the EU market, you are the operator. Access2Markets says you submit the due diligence statement in the EU Information System and keep and pass on its reference number. The due diligence behind that statement is commonly summarised as three steps: gather information on where the cocoa was grown, assess the risk that it is linked to deforestation or illegal production, and reduce any risk found before filing. Read the obligations in Regulation 2023/1115 itself with your adviser.
Downstream operators and traders
Under the amendment, businesses further down the chain, such as a chocolate maker buying beans from an Italian importer, no longer submit their own statements. They must collect and keep the reference number of the initial declaration from the operator that first placed the product on the market.
Micro and small primary operators
Access2Markets says micro or small primary operators in low-risk countries submit a single simplified declaration instead, with content set out in a new Annex III. Whether that helps a Nigerian supply chain depends on Nigeria’s risk classification under the regulation, which the page does not state; check the Commission’s country benchmarking list.
What to ask your Nigerian supplier now
- Geolocation of the farms or plots the cocoa came from, in a format your due diligence system can use.
- How it separates traceable cocoa from cocoa bought through middlemen.
- Evidence that production was legal under Nigerian law, including land use.
- Whether it will supply the same data for every shipment, and what happens to the price if it must.
The rest of the paperwork has not changed
The EUDR adds to normal import requirements. Your Nigerian exporter still files Form NXP and needs payment within the CBN’s repatriation window (see NXP explained); you still need an EORI, a customs declaration and food safety compliance; and you can claim a preferential rate with a valid statement on origin (see origin and EU duty).
If you buy through another EU country
Many Italian buyers receive Nigerian cocoa that first entered the EU through another port, such as Amsterdam or Antwerp. In that case the company that first placed it on the EU market is the operator, and your obligation as a downstream buyer is to obtain and keep its statement reference. Put that requirement in your purchase contract from now on.
A worked example
Example only: a Turin chocolate maker buys Nigerian beans through a Genoa trader, which imports them. From 30 December 2026 the trader, as operator, files the due diligence statement; the chocolate maker, as downstream operator, records the trader’s statement reference against each delivery and keeps it with its purchase records.
Where Pryme fits
Traceability costs money at origin, and Nigerian suppliers may ask for part of it up front. A Pryme Business Account can pay a Nigerian exporter in euros, dollars or naira, with each rate and fee shown before you approve, and the Compliance agent can prepare a document checklist per shipment for a person to sign off. Outside Nigeria, Pryme’s services are provided through regulated partners. See the Compliance agent.
Questions people ask
When does the EUDR apply to cocoa importers?
From 30 December 2026 for large and medium operators, and 30 June 2027 for most micro and small operators, under Regulation (EU) 2025/2650 as described by the Commission.
Does a chocolate maker buying from an Italian importer file a due diligence statement?
Under the amendment, downstream operators and traders do not file their own; they keep the reference number of the initial declaration.
What is the simplified declaration?
A single declaration for micro or small primary operators in low-risk countries, with content in a new Annex III.
Has Nigeria been classified as low, standard or high risk?
The Commission page cited does not say. Check the Commission’s country benchmarking list.
Sources
- European Commission Access2Markets: Delay until December 2026 and other developments in the implementation of the EUDR (28 Jan 2026) · accessed Oct 2026
- Confectionery News: EUDR delay confirmed (17 Dec 2025) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.