This Anti-Corruption Helpdesk brief was produced in response to a query from a U4 Partner Agency. The U4 Helpdesk is operated by Transparency International in collaboration with the U4 Anti-Corruption Resource Centre based at the Chr. Michelsen Institute.
Query
Could you please provide an overview of the land corruption risks that could undermine the implementation of the EU deforestation regulation (EUDR)?
Summary
EU regulation on deforestation-free products (EUDR) aims to reduce Europe's contribution to global forest loss by requiring proof that commodities entering EU markets are deforestation-free and legally produced. It introduces a comprehensive due diligence system, though its effectiveness depends on the integrity of land governance in source countries and supply chains. This Helpdesk Answer examines how specific corruption risks may undermine the implementation of the EUDR, drawing on existing evidence from cocoa, timber and other sectors, and outlines practical mitigation strategies, including integrated data systems, beneficial ownership transparency and strengthened civil society monitoring.
Main points
- Agricultural activities account for about 90% of global forest loss, with timber, palm oil and cocoa being particularly significant commodities. European over-consumption acts as a core driver, positioning the EUDR as a necessary policy response to this demand-side issue.
- Corruption threatens to undermine the three EUDR pillars (deforestation-free, legality and due diligence). Acts such as falsifying land registry data, bribing forestry officials and manipulating cadastral records could enable deforestation-linked commodities to still enter EU markets under a false veneer of compliance.
- Supply chain complexity also creates manipulation opportunities. Fragmented commodity chains with multiple intermediaries enable corrupt actors to mix illegal products with legal batches, falsify origin certificates and obscure true production sources. These risks are particularly prevalent in cocoa sectors where only 40% of supply is directly traceable.
- Integrated data systems offer a high-impact, replicable anti-corruption model. Ghana's approach, which links forest, cocoa, land administration and environmental data across agencies, creates a traceable and accountable framework that significantly inhibits fraudulent conversions and illegal permits.
- The EUDR's long-term success hinges on catalysing lasting governance reforms. Experts argue that market access conditionality should be strategically applied to counter rent-seeking, bolster domestic reform allies, protect smallholders from exclusion and strengthen institutional integrity in producer countries.
Authors
Sebastiana A. Etzo
Reviewers
Jamie Bergin, Gvantsa Gverdtsiteli (TI)
David Aled Williams (U4)
Date
12/12/2025
