ISPO as a Path to EUDR Compliance: Strengthening Existing Standards, Not Creating New Ones

Peta kebun sawit, perangkat geolokasi, jalur ketertelusuran, hutan, dan pelabuhan ekspor.

Sources monitored: 28 September 2026.

The European Union Deforestation Regulation (EUDR) is increasingly framed as a new challenge for Indonesian palm oil. Official sources and stakeholder statements, however, point to a more practical line: EUDR compliance does not need to start with a new standard. It can start by strengthening existing standards — above all Indonesian Sustainable Palm Oil (ISPO) certification, Indonesia's mandatory national sustainability scheme — so that data, traceability, legality and deforestation-free elements can meet the due-diligence needs of the EU market.

This position was set out in the context of cooperation between WWF-Indonesia and the Council of Palm Oil Producing Countries (CPOPC), the intergovernmental body of palm oil-producing countries. ANTARA reported that WWF-Indonesia believes ISPO can be strengthened, including on the deforestation-free element, to support compliance with EUDR requirements. WWF-Indonesia CEO Aditya Bayunanda said the cooperation with CPOPC is aimed at bridging the sustainability demands of global markets with conditions in producer countries. He also stressed that the cooperation is not about creating a new standard or system, but about strengthening the standards already in place.

Seen this way, ISPO can serve as a national foundation. ISPO is a certification system built by Indonesia to promote sustainable palm oil practices. EUDR, by contrast, is a due-diligence regime governing specific goods when they are placed on, or exported from, the EU market. The distinction matters. National certification can help supply data, evidence of practices and verification mechanisms, but EUDR still requires operators to carry out due diligence on products within the regulation's scope.

Reading the official deadlines correctly

The latest update on the European Commission's Access2Markets portal states that Regulation (EU) 2025/2650, published in December 2025, further postpones application of the EUDR to the end of 2026. With that change, the main obligations of Regulation (EU) 2023/1115 apply from 30 December 2026 for large and medium-sized operators and certain other supply-chain actors, while operators that are natural persons, micro-enterprises or small enterprises have until 30 June 2027 for other EUDR products. The same information appears in ANTARA's report on ISPO and the EUDR, including the note that micro and small enterprises previously covered by the European Union Timber Regulation start applying the rules on 30 December 2026.

The deadline gives room to prepare, but does not change the substance of the obligations. The EUDR covers seven commodities, including oil palm, and a number of derived products. Products in scope must be deforestation-free and produced in accordance with the laws of the country of production. Indonesia's preparation therefore cannot simply wait for the application date. The work that needs to be accelerated is making sure that data on plantations, legality, supply chains, transactions and deforestation-free evidence are available in a format buyers and operators can use.

ISPO is not a substitute for due diligence

The European Commission explains that EUDR due diligence consists of three steps: information collection, risk assessment, and risk mitigation where risk is not zero or negligible. At the information stage, operators must collect data on the product, quantity, suppliers, country of production, evidence of legality and the geographic coordinates of the plots of land where the commodity was produced. If the required information cannot be collected, the product may not be placed on the EU market or exported.

In the risk-assessment step, operators assess the likelihood that non-compliant products have entered the supply chain, taking into account, among other things, the presence of forests and indigenous peoples, the prevalence of deforestation, supply-chain complexity and the strength of law enforcement. If risk remains, operators must take adequate and proportionate mitigation measures. These can include requesting additional information, independent surveys or audits, and compliance support for suppliers — including smallholders — through capacity building and investment.

This is where the boundary between ISPO and the EUDR must be read clearly. Certification and third-party verification schemes can provide complementary information in the risk assessment, but they do not replace the operator's responsibility to carry out due diligence. Claims that ISPO is automatically equivalent to the EUDR are therefore potentially misleading. A stronger formulation is that ISPO can become a path to compliance if it is strengthened on the elements the EUDR requires: deforestation-free status, geolocation, legality, traceability, transaction records and verifiable evidence.

The institutional groundwork already exists

ANTARA noted that the Indonesian government is developing the Indonesian Sustainable Palm Oil Information System (SI-ISPO) to integrate certification processes and the traceability of palm products. The system is designed to link certification data with geolocation information, transaction types and volumes, information needed by buyers or importers, and data from several ministries and agencies. In the EUDR context, this kind of integration matters because the weak point in compliance is often not sustainability principles as such, but the ability to prove a product's origin and link it to buyers' requirements.

The certification base is already substantial. Citing data from the National Standardisation Agency (BSN) presented by the Coordinating Ministry for Economic Affairs, ANTARA reported that, as of June 2026, ISPO certificates had been issued to 1,053 business entities covering 7.52 million hectares, of which 881 certificates were still valid. In the grower category, ISPO certificates had been issued to 144 entities covering 355,122.33 hectares, with 114 certificates still valid covering 283,135.56 hectares.

These figures show that strengthening ISPO does not start from zero. The certification infrastructure, institutions and verification experience already exist. The challenge is to connect existing systems with the EUDR's evidentiary requirements, especially in supply chains involving many suppliers, collectors, mills and smallholders. Readers can follow GIMNI's Wawasan (Insights) archive (in Indonesian) for palm oil sustainability issues within a broader industry-education framework.

Smallholders must not become the weak link

Palm Oil Magazine reported that the WWF-Indonesia and CPOPC cooperation places supply-chain transparency, certification, EUDR compliance, biodiversity protection and smallholder engagement at its centre. A webinar accompanying the signing of the memorandum of understanding highlighted requirements such as geolocation, traceability and documentation, which can be major challenges for smallholders seeking to stay connected to international supply chains.

CPOPC Secretary-General Izzana Salleh, as quoted by ANTARA, stressed that sustainable palm oil cannot be achieved without smallholders. She said smallholders manage around 41% of Indonesia's oil palm area. Ministry of Agriculture data cited in the same report show that Indonesia's oil palm plantation area as of 2025 was around 16.83 million hectares, of which 6.93 million hectares were smallholder plantations.

The consequence is that the EUDR compliance agenda cannot be left only to large companies or exporters. If geolocation, legality and traceability data are not available at smallholder level, a risk of market exclusion may arise. WWF-Indonesia, according to ANTARA, believes government support is still needed so that smallholders are not left behind and retain market access. Within the EUDR framework, such support is consistent with the European Commission's guidance that risk mitigation can include compliance support for suppliers, particularly smallholders, through capacity building and investment.

Market access and incentives as drivers

Strengthening standards costs money. In a separate report, ANTARA noted that WWF-Indonesia sees market access and market incentives as key to ensuring that sustainable practices in Indonesian palm oil continue to develop while delivering economic benefits for producers, especially smallholders. Aditya Bayunanda said achieving sustainability requires effort and investment, so producers need a return in the form of market access and opportunities to enter new markets.

This message clarifies the link between compliance and economics. If strengthening ISPO, SI-ISPO and supply-chain documentation is treated only as an administrative burden, small players will struggle to keep up. If, on the other hand, stronger standards help maintain market access and open trade opportunities, compliance can become an investment. ANTARA also linked the market context to preparations for the Indonesia–European Union Comprehensive Economic Partnership Agreement, which is expected to open access to the EU market and grant zero tariffs on palm oil and its derivatives once in force (see I-EU CEPA opens a zero-tariff opportunity for Indonesian palm oil).

In conclusion, the realistic path is not to treat ISPO and the EUDR as two systems that replace each other. ISPO is a national asset that needs strengthening; the EUDR is a due-diligence obligation that operators must meet according to their role in the supply chain. Strengthening existing standards, integrating data, supporting smallholders and creating market incentives are the way to ensure that compliance does not become a new barrier, but a means of improving the acceptance of sustainable Indonesian palm oil in global markets.