<!-- https://farmer1st.org/en/glossary/risk-mitigation/ · updated 2026-09-28 -->
# Risk mitigation (EUDR)

> Under the EUDR, risk mitigation is the third step of due diligence: where risk assessment finds a non-negligible risk, the operator adopts adequate measures, such as requiring more information, independent surveys or audits, or supporting suppliers, until the risk becomes negligible.

Also known as: Article 11 risk mitigation

## Why does it matter?

Under Article 11 of the [EUDR](/glossary/eudr/), mitigation is mandatory whenever [risk assessment](/glossary/risk-assessment/) does not conclude that risk is none or [negligible](/glossary/negligible-risk/). Decisions must be documented, reviewed at least annually and made available to authorities.

## What measures are typical?

Article 11 lists:

- requiring additional information, data or documents;
- carrying out independent surveys or audits;
- other measures on the information requirements;
- supporting suppliers, in particular [smallholders](/glossary/smallholder/), through capacity building and investments.

In a first-mile context, this can mean re-mapping plots with a flagged polygon, a field visit to check an alert, collecting tenure documents, excluding a plot from a lot, or training farmers.

Non-SME operators must also have policies, controls and procedures, including a compliance officer at management level and an independent audit function (Article 11(2)).

## Common pitfalls

- Treating exclusion of farmers as the only mitigation tool, which can push risk elsewhere and harm livelihoods.
- Mitigating on paper without re-assessing the risk afterwards.
- No record of why a flagged plot was cleared.

Farmer1st sends verification tasks to field teams and tracks their outcomes through its [field agent management](/services/field-agent-management/) service.


## Frequently asked questions

### What if risk cannot be mitigated?

The operator must not place the product on the market or export it. Article 4(4) prohibits placing where due diligence revealed a non-negligible risk.

### Can supporting smallholders count as risk mitigation?

Yes. Article 11(1) states that mitigation may include supporting compliance by the operator's suppliers, in particular smallholders, through capacity building and investments.


## Sources

- [Regulation (EU) 2023/1115 (EUDR), EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng)
- [OECD-FAO Guidance for Responsible Agricultural Supply Chains](https://www.oecd.org/en/publications/oecd-fao-guidance-for-responsible-agricultural-supply-chains_9789264251052-en.html)
