Closing the Data Gap: Digital Public Infrastructure for Forest Risk Commodities
A blog by the Frontier Tech Hub
Pilot: Protecting Forests: Open Data for Supply Chain Due Diligence
Agricultural expansion is a significant driver of global deforestation. To address this, regulatory frameworks – such as the EU Deforestation Regulation (EUDR), the US Lacey Act and UK Forest Risk Commodities (UKFRC) - are emerging that aim to ensure that commodities closely linked to deforestation are sourced responsibly. This imposes due diligence and traceability requirements across all aspects of the supply chain, but creates particular difficulties for smallholder farmers and actors upstream, who are the least likely to have the capacity to demonstrate compliance. There is a risk that smallholder farmers that are unable to demonstrate compliance within new regulations are more likely to be excluded from the supply chain entirely as a result.
In response to this, the FT Hub in partnership with the FCDO and Proforest supported a discovery phase research project exploring the challenges faced by actors in Forest Risk Commodity (FRC) supply chains, and the potential for Digital Public Infrastructure (DPI) tools to allow for open and effective transfers and generation of data. DPI refers to foundational digital systems, often open-source and interoperable, that enable inclusive, reliable and transparent data collection and sharing across the supply chain. Broadly, the project aims to answer three questions:
● What data and information are likely to be needed by different supply chain actors to comply with emerging FRC regulations in consumer markets?
● How prepared and able are supply chain actors to meet regulation requirements and data demands? Based on the nature of the technical landscape and the incentives of different market actors, what needs, barriers and pain points are different actors likely to have in demonstrating compliance with emerging requirements?
● What interventions are required to address the needs and barriers we believe actors will face in generating and accessing the data needed to demonstrate compliance with legislation?
Several key emerging regulations were examined across the EU, UK and US. These included the aforementioned EUDR, US Lacey Act, and UKFRC, as well as the EU Timber Regulation (EUTR) and the US Forest Act. Findings from this research show that regulations vary widely in their data requirements, reflecting how approaches to traceability, legality and deforestation have changed over time. In particular, EUDR requires the most comprehensive traceability data, down to individual farm plots.
Using case studies of cocoa in Ghana and palm oil in Indonesia, the report assesses the demands currently placed on supply chain actors and the data challenges and gaps that actors are likely to face in demonstrating compliance. These gaps include competing incentives – such as local tax systems, misalignment between national and international laws, and lack of capacity. Existing DPI efforts, such as Ghana’s Cocoa Traceability System or Indonesia’s National Dashboard, offer a promising, long-term path to credible data collection but have several barriers and needs to be addressed before they can scale effectively and inclusively.
While a recent proliferation of private sector solutions demonstrates the increasing investment put into closing data gaps, they typically lead to siloed B2B digital tools, often developed top-down and in isolation. It is crucial that systemic capacity building takes place to ensure producers are able to take ownership of these solutions, and that these are built with long-term data generation and sustainability of the tool in mind.
As B2B solutions will have limited impact and lead to duplication of costs and efforts, different types of public data sets and tools are being developed at global and national levels to address data gaps and challenges in an inclusive manner. Examples developed by DIASCA, AIM4Forests and the Forest Data Partnership offer a more inclusive and sustainable business model, leading to more consistent and inclusive access to data. The report expands on the current ecosystem of DPI tools and the priority areas for improvement as outlined by experts.
The report concludes with a set of key recommendations for building a more functional, coherent, and inclusive DPI to support FRC supply chains. These include harmonising data efforts between private sector actors and national governments to prevent duplication and inefficiency, and actively involving national governments in DPI discussions to identify opportunities, address gaps, and share lessons learned. It also calls for improving the availability and consistency of legality risk data to support downstream companies in meeting due diligence obligations, alongside enhanced digitalisation and public disclosure of legality evidence - particularly in contexts where such data remains fragmented or inaccessible.
Read the discovery report in full by clicking below:
If you’d like to dig in further…
Publish date: 22/07/2025
Image credit: iStock
