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A postponement of the application date of the due diligence requirements from August 18, 2025 to August 18, 2027, whereby they will publish their guidelines by July 26, 2026 instead of the date of February 18, 2025 that has now expired. Some reasons given by the Commission for postponing the date:

• Companies need more time to prepare because of the changed geopolitical situation.
• There are no guidelines from the Commission for due diligence yet, and the Commission wants to ensure consistency with the Corporate Sustainability DueDiligence Directive (2024/1760) which was only adopted after the Battery Regulation. The Commission therefore wants to draft the guidelines together with those for the general due diligence directive in order to clarify and simplify the application of the requirements.
• In half of the countries (including Belgium) there are no notified bodies available for conformity assessment.
• There is no harmonised standard for accreditation in connection with the due diligenceobligation. The European Accreditation Coordination Organisation (EA) has indicated that this should be done through schemes approved by the Commission, but there are currently none.

Indeed, Article 47 of the Battery Regulation exempts SMEs from certain obligations regarding battery due diligence policy. SMEs are described here as 'economic operators with a net turnover of less than €40 million in the financial year preceding the last financial year, and which are not part of a group consisting of parent companies and subsidiaries, which exceeds the limit of €40 million on a consolidated basis'. 

The scope of this provision should be extended to small mid-cap companies (SMEs) according to the Commission's simplification proposal, so that they are also exempted from these obligations. To ensure consistency, SMEs should be defined in the same way, taking into account that they are entities three times the size of SMEs, i.e. based on a net turnover that must therefore be less than 150 million euro. 

In accordance with Article 52, economic operators referred to in Article 48(1) are required to review and make publicly available, on an annual basis, their battery due diligence policies, including on the internet. In order to reduce the administrative burden on economic operators, the Commission considers that this obligation to review and disclose their due diligence policy should be amended so that it  applies every three years instead of annually.