New obligations for businesses in 2027. Why is regulatory compliance becoming increasingly important?

The year 2027 will bring further significant changes to EU and national legislation affecting businesses. New requirements relating to product safety, batteries, supply chains, imports, environmental protection and cybersecurity will require many companies to adapt their documentation, procedures and operational processes. Increasingly, however, the challenge lies not only in implementing individual regulations, but also in correctly identifying all the obligations that apply to a particular business.

2027 — further changes to the regulatory environment for businesses

In recent years, businesses operating in the EU market have faced a growing number of regulations affecting the way they conduct their activities.

These changes extend beyond environmental protection in its traditional sense or reporting obligations. They increasingly cover product safety, technical documentation, the responsibilities of importers and distributors, the traceability of goods, and the organisation of international supply chains.

The year 2027 will be particularly significant in this respect, as further stages in the application of a number of EU regulations begin.

The most important changes include:

1. Machinery Regulation — from 20 January 2027

Regulation (EU) 2023/1230 will replace the existing Machinery Directive 2006/42/EC. The new rules cover, among other things, requirements for machinery safety, conformity assessment, technical documentation and the responsibilities of entities involved in placing machinery on the market.

The changes will be relevant not only to machinery manufacturers, but also to importers, distributors and businesses making substantial modifications to equipment.

2. Batteries Regulation — new obligations from 18 February and 18 August 2027

Regulation (EU) 2023/1542 provides for further stages in the implementation of requirements for batteries and accumulators.

From 18 February 2027, provisions will apply concerning, among other things, the removability and replaceability of certain categories of batteries and digital passports for industrial batteries with a capacity greater than 2 kWh, electric vehicle batteries and light means of transport batteries.

Battery raw material supply chain due diligence obligations will then apply from 18 August 2027. In this context, the EUR 40 million net turnover threshold is particularly relevant. It is assessed in accordance with the rules set out in the Regulation, taking into account relevant relationships within corporate groups.

3. EUDR — a further stage of application from 30 June 2027

Regulation (EU) 2023/1115 on deforestation-free products provides for the rules to apply to certain micro and small enterprises from 30 June 2027.

The Regulation covers the commodities and derived products specified in it, and its relevance extends beyond the agricultural and forestry sectors. It may also affect manufacturers, importers, exporters and distributors using the relevant raw materials or products in their operations.

For large and medium-sized enterprises, the general application date is 30 December 2026, meaning that compliance with these obligations will also need to be monitored throughout 2027.

4. Microplastics under REACH — new reporting obligations by 31 May 2027

Commission Regulation (EU) 2023/2055 provides for an extension of reporting obligations relating to synthetic polymer microparticles.

By 31 May 2027, certain groups of manufacturers, industrial downstream users and suppliers will be required to submit information to the European Chemicals Agency covering, among other things, the uses of microparticles and estimated emissions to the environment in 2026.

The Regulation may also be relevant to businesses that do not manufacture plastics directly but use the relevant raw materials or mixtures in industrial processes.

5. CBAM — the first annual declaration and surrender of certificates by 30 September 2027

The Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase in 2026.

By 30 September 2027, authorised CBAM declarants subject to the relevant obligations will be required to submit their first annual CBAM declaration, covering imports in 2026, and surrender the corresponding number of certificates.

For importers, this means ensuring that data on imported goods and their associated emissions is of sufficient quality, and correctly determining the scope of their obligations, taking into account the applicable exemptions and thresholds.

6. Cyber Resilience Act — new requirements from 11 December 2027

Regulation (EU) 2024/2847 on cyber resilience for products with digital elements introduces cybersecurity requirements for products.

The main provisions will apply from 11 December 2027, covering, among other things, secure product design, vulnerability management and demonstrating conformity with specified requirements.

Some obligations, including those relating to the reporting of certain vulnerabilities and incidents, have already applied since September 2026.

New obligations are not limited to new regulations

In 2027, businesses will also need to meet obligations arising from regulations that became applicable earlier.

One example is the Packaging and Packaging Waste Regulation (PPWR), which generally applies from 12 August 2026. For many businesses, the following months will be a period of practical adjustments to documentation, purchasing procedures, cooperation with suppliers and processes for verifying packaging compliance.

In parallel, requirements under the Ecodesign for Sustainable Products Regulation (ESPR) will continue to be developed, including arrangements for digital product passports. Specific obligations will depend on the relevant delegated acts and their application dates.

Business operations may also be affected by changes to national legislation, particularly in the areas of taxation, energy, waste management, and registration and reporting obligations.

Crucially, the list of changes is not exhaustive. Legislative work continues at both EU and national level that may affect the scope of business obligations, their deadlines and enforcement arrangements.

The greatest challenge is determining which regulations actually apply to a business

In practice, interpreting a new provision is not always the main difficulty.

A business engaged in manufacturing, importing or distribution may simultaneously be subject to regulations covering product safety, environmental protection, waste management, excise duty, energy, transport and international supply chains.

Moreover, the scope of its obligations often depends on specific circumstances, such as:

• the business’s role in the supply chain — manufacturer, importer, distributor or other economic operator;

• the type, composition and classification of goods;

• the origin of products and how they are placed on the market;

• the size of the business or corporate group;

• the business model, including imports, intra-Community acquisitions of goods, contract manufacturing or cross-border sales.

For this reason, simply knowing when legislation enters into force is not enough.

The key is to translate regulatory requirements into the specific context of the business and determine what action is needed, who should be responsible for it and by when it must be completed.

Failure to identify obligations correctly can lead not only to administrative or financial penalties, but also to difficulties placing products on the market, delivery delays, additional operating costs or disruptions to business relationships.

Regulatory compliance — from monitoring legislation to managing obligations

As the legal environment becomes more complex, a systematic approach to regulatory compliance is becoming increasingly important.

Its purpose is not only to ensure compliance with applicable legislation, but above all to identify changes early enough, assess their impact on business operations and plan the adjustments required.

In practice, this approach may cover four main areas:

Monitoring regulatory changes — ongoing analysis of EU and national legislation, legislative proposals, guidance from authorities and changes to the application dates of individual regulations.

Assessing the impact of regulations on business operations — identifying requirements that actually apply to products, processes, import models, sales and supply chains.

Mapping regulatory obligations — organising requirements, deadlines, necessary documentation and actions to be completed by individual organisational units.

Supporting the adjustment process — assistance with interpreting legislation, developing procedures and documentation, and implementing solutions that ensure regulatory compliance.

Understood in this way, compliance enables businesses to move from reacting to individual legislative changes towards more predictable management of their obligations.

Ongoing regulatory compliance support — a solution for businesses

T&P Advisory, part of Thedy & Partners, offers businesses regulatory compliance support covering both ongoing monitoring of legislative changes and analysis of their impact on business operations.

The service may cover environmental, product, energy, tax and transport regulations, as well as requirements relating to international supply chains.

The scope of support is tailored to the nature of the business, the types of products it offers, its target markets and its operating model.

An important element of this approach is filtering regulatory information. Businesses receive not just notification of a legislative change, but, above all, an assessment of whether a particular regulation may be relevant to their operations, what obligations it may create and what action they should consider.

Ongoing cooperation may include periodic reviews of the regulatory environment, summaries of upcoming obligations, risk identification and support with implementing the necessary adjustments.

This allows organisations to focus their resources on relevant risks and requirements, reducing the need to independently analyse numerous legislative changes that are often unrelated to their business.

Preparations for 2027 should begin in 2026

For many businesses, the final months of 2026 are a suitable time to review their regulatory obligations and prepare an action plan for the following year.

In particular, businesses should check which regulations will apply to their operations, which obligations require advance preparation, and whether their current procedures and allocation of responsibilities will ensure timely compliance.

The year 2027 shows that regulatory compliance is becoming more than a purely legal matter. Increasingly, it is becoming part of managing operational risk, business continuity and the security of business operations.

In these circumstances, systematic regulatory monitoring and early identification of obligations can be just as important as implementing new legislation itself.

Contact

Businesses interested in identifying their regulatory obligations for 2027, assessing the impact of legislative changes on their operations or obtaining ongoing regulatory compliance support are invited to contact:

Krzysztof Wiński
Managing Partner, T&P Advisory | Thedy & Partners
krzysztof.winski@thedy.pl
tel. +48 519 506 434

Łukasz Pamuła
Senior Manager, T&P Advisory | Thedy & Partners
lukasz.pamula@thedy.pl
tel. +48 519 504 779