EUROPEAN COMMISSION

Brussels, 10.12.2024

SWD(2024) 360 final

COMMISSION STAFF WORKING DOCUMENT

Simplification measures for farmers

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Regulations (EU) 2021/2115 and (EU) 2021/2116 as regards good agricultural and environmental condition standards, schemes for climate, environment and animal welfare, amendments to CAP Strategic Plans, review of CAP Strategic Plans and exemptions from controls and penalties

{COM(2024) 139 final/2}

CONTENTS

1. INTRODUCTION

2. POLITICAL AND LEGAL CONTEXT

3. CONSULTATION STRATEGY AND EVIDENCE GATHERING

3.1. Consultation of EU farming organisations, Member States, and the Committee on Agriculture and Rural Development of the European Parliament

3.2. Consultations specific to individual measures

3.3. Gathering further evidence

4. OPTIONS CONSIDERED AND THE CHOICE OF INSTRUMENTS FOR THE PROPOSED SOLUTION

4.1. Common agricultual policy (CAP) strategic plans: management, administration and checks

4.2. CAP strategic plans: the green architecture

4.3. Farm income and competitiveness

4.4. Other CAP instruments

4.5. Legislation outside the CAP    

5. DESCRIPTION OF THE ACTIONS TAKEN

5.1 CAP strategic plans: management, administration and controls

5.2. CAP strategic plans: the green architecture

5.3 Farm income and competitiveness

5.4 Other CAP instruments

5.5 Elements outside the CAP

6. MAIN IMPACTS OF THE SIMPLIFICATION MEASURES

6.1 Impacts on the administrative burden for beneficiaries and national administrations

6.2 Other economic impacts

6.3 Environmental impacts

6.4 Social impacts

6.5 Impacts relating to the performance, monitoring and evaluation framework

7. CONCLUSIONS

ANNEXES

Annex 1. Actions announced by the Commission on 22 February 2024 and their delivery    

Annex 2. Overview of the received simplification suggestions    

Annex 3. Impact analysis. Who is affected and how?    

Annex 4. Modelling the impact of removing the GAEC 8 first requirement (share of non-productive areas and elements in arable land) according to the IFM-CAP model.    

Glossary

1.INTRODUCTION

On 22 February 2024 the Commission put forward a simplification package of measures to ease the administrative burden on farmers and help them tackle the challenges that had arisen since the reform of the common agricultural policy (CAP) for 2023-2027 1 . The measures that were announced are presented in Annex 1. 

On 15 March 2024, the Commission proposed 2  targeted changes to the underlying CAP basic legislation (the CAP Strategic Plan Regulation and the Horizontal Regulation) 3 to deliver simplification while maintaining the overall orientation of the current CAP and its role in supporting the transition of European agriculture to sustainable farming. Without changes in substance, the proposal was adopted by the co-legislators and then published on 24 May 2024 4  (the Simplification Regulation). These measures are accompanied by changes to some of the detailed rules of the CAP set in the secondary legislation, and by other measures to reduce the administrative burden on farmers as part of the Commission’s wider policy to rationalise reporting obligations, launched in 2023 5 .

This document takes stock of progress in implementing the simplification package, which includes the Commission proposal of 15 March 2024. It outlines the key challenges, the process, the results of the consultations that fed into the package, and the different options considered. Following a presentation of the solutions that were found, it provides a qualitative and, where feasible, quantitative assessment of their costs and benefits from administrative, economic, environmental, social and governance perspectives.

Throughout this document, actions derived from the Commission’s announcement of 22 February 2024, including legislative proposals or delegated and implementing acts, are referred to hereafter as ‘the simplification package’.

2.POLITICAL AND LEGAL CONTEXT 

The reformed CAP for 2023-2027

The CAP for 2023-2027 aims to foster a smart, competitive, resilient and diversified agricultural sector that ensures our long-term food security. It also aims to support and strengthen environmental and climate protection, and to strengthen the socio-economic fabric of rural areas.

At operational level, 28 CAP Strategic Plans 6  (CAP Plans 7 ) were drawn up by the Member States, approved by the Commission and first applied in 2023. A set of requirements, interventions and targets across 10 CAP specific objectives detail the abovementioned ambitions of the CAP, measured by common indicators. In combination with EU regulatory initiatives, research, investments and other actions to meet the EU’s environmental and 2050 climate objectives, the CAP Plans contribute to the Commission’s Green Deal agenda.

Compared to period before 2023, the reformed CAP represents a shift towards a performance-based model, aiming for a more strategic and targeted planning (the new delivery model, NDM). It is also a step forward in terms of simplification and increased flexibility.

Bringing direct payments, sectoral and rural development types of interventions encompassing two funds 8 under a single strategic tool (CAP Plans) was a major change to the CAP. Member States gained greater flexibility to design and target their interventions to best address their specific circumstances, thus improving consistency and complementarity of how the funds are spent. Under this approach, Member States play a key role in keeping the administrative burden for farmers limited and proportionate. The new approach also posed certain challenges in ensuring common standards, and that efforts were comparable and aligned with each other. Any successful simplification that sustains the ambition of a high level of collective effort requires close cooperation between the Commission, the administrations in Member States and the farmers themselves. 

The 2024 simplification agenda

The Commission’s 2023 assessment of the CAP Plans’ joint effort and collective ambition in addressing the CAP’s objectives 9  concluded that the new approach was appropriate to pursue the policy objectives but signalled the need to keep the administrative burden under review. 

While the new approach is working well overall, the first year of operation of the CAP Plans made it clear that adjustments were necessary to ensure that they bring the expected effects and to cut red tape. The first year also showed that there is a need to take better account of the impacts of Russia’s war of aggression against Ukraine, which strongly influenced the markets (and farmers’ margins), as well as the overall context for the EU’s agricultural policy. The discussions on several related Green Deal legislative proposals were also relevant as they may affect both farmers and the requirements set out in the CAP Plans. The reasons for the widespread protests by farmers in early 2024 are complex but reflected these concerns, as well as other major structural, economic and climatic challenges in agriculture and in rural areas.

The European Council of 1 February 2024 discussed the challenges in the agricultural sector, including the concerns raised by farmers during the protests. Stressing the essential role of the CAP, it called on the Council and the Commission to take the work forward as necessary.

Commission President Ursula von der Leyen committed to launch a thorough analysis of the administrative burden on farmers to identify areas for improvement. Based on input from, among others, the Member States, EU farmers’ organisations and the European Parliament, the Commission came forward with a non-paper on possible simplification actions on 22 February 2024 as an input to Council discussions (‘the simplification package’).

The Agriculture and Fisheries (AGRIFISH) Council of 26 February 2024 confirmed its political will to respond effectively to the concerns of farmers and, as a first step, supported a range of measures in the Commission’s simplification package as a priority for the short-term response. It also insisted that a review of the CAP’s basic acts is necessary as soon as possible. The Committee on Agriculture and Rural Development of the European Parliament also discussed the simplification package on 26 February 10 .

On 15 March 2024 the Commission proposed to change certain provisions of the CAP related to the implementation and management of CAP Plans and certain instruments for environment and climate. Following the approval of the European Parliament and the Council with no modifications on substance, the adopted legislation was published on 24 May 2024 11  (the Simplification Regulation). Several other legislative and non-legislative actions set out in the simplification package have also been completed or are underway.

Reducing the administrative burden of EU policies is a Commission priority since it is considered crucial to the EU’s competitiveness 12 . Simplification of EU policies affecting agriculture is a concern, both at EU and national level, and a number of short-term measures to rationalise reporting requirements were already being prepared before January 2024. The parts of the simplification package that will help reduce reporting obligations have been integrated into the rationalisation plan of the Commission’s Directorate-General for Agriculture and Rural Development (DG AGRI). Further actions may be added at a later stage.

Related activities

During their protests, farmers raised concerns about the fairness of the remuneration for their work, an issue that was also raised in debates with Member States, the European Parliament’s Committee on Agriculture and Rural Development and stakeholders. Farmers also complained about unfair competition from agricultural products from non-EU countries, which do not apply the same standards during the production process. Along with the simplification package, on 15 March 2024, the Commission presented several options to address this challenge by improving farmers’ position in the agri-food supply chain 13 and protecting them against unfair trading practices. The Commission presented these options to the AGRIFISH Council on 26 March 2024. Implementation of these actions is already underway.

To provide a long-term perspective to farmers, on 25 January 2024 President von der Leyen launched the Strategic Dialogue on the Future of Agriculture in the EU 14 . It gathered actors across the whole agri-food supply chain, as well as non-governmental organisations and civil society representatives, financial institutions, and researchers. By combining different perspectives, the dialogue aimed to foster the creation of new solutions and to bring about a common vision for the future of agriculture in the EU. This dialogue resulted in a report delivered on 4 September 2024 15 , in time for the new College, which took office on 1 December 2024, to prepare its priorities.

3. CONSULTATION STRATEGY AND EVIDENCE GATHERING

3.1. Consultation of EU farming organisations, Member States, and the Committee on Agriculture and Rural Development of the European Parliament

In view of the widespread farm protests, the Commission asked four main EU-level organisations representing farmers to suggest measures at EU level (CAP and other EU legislation) to reduce the administrative burden weighing on farmers’ shoulders. A similar request was made by the Belgian Presidency of the Council to agriculture ministers. 
The European Parliament’s Committee on Agriculture and Rural Development also informed the Commission of the areas that it considered needed concrete and immediate action.

The urgency of the situation meant that it was not possible to conduct the more usual, wider consultation process. This ad hoc consultation process lasted one week and resulted in a wide range of suggestions that fed into the Commission’s reflections on the scope and focus of the measures to take.

·The responses from Member States were wide in scope, with some citing practical challenges that could feasibly be addressed in the short term, while many other responses were far-reaching and went beyond the issues of reduction of the administrative burden, simplification of implementation or a stable and consistent policy framework for farmers.

·The consultation of farming organisations resulted in calls for urgent action to simplify the administrative burden on farmers, but also stressed the need for a stable and consistent policy framework, proposing further reforms for the longer-term.

·Similarly, the European Parliament’s Committee on Agriculture and Rural Development identified several priority areas of work. These included suggestions to simplify procedures for the Commission to approve amendments of CAP Plans, and to make certain environmental rules more flexible. Other suggestions were aimed at improving the competitiveness of EU farmers, such as promoting mirror clauses in all trade agreements, revising the Unfair Trading Practices (UTP) Directive, improving the situation of farmers in the agri-food supply chain also by looking at competition rules, and carrying out an assessment of Green Deal legislation related to agriculture. 

Section 4 and Annex 2 summarise these suggestions and provide the Commission’s assessment.

3.2. Consultations specific to individual measures

On several individual measures of the simplification package, the Commission organised exchanges and consultations involving experts from all 27 Member States either within the Common Agricultural Policy Committee set up under the CAP Plan Regulation, or the Expert Group on the implementation of the CAP Plans.

These consultations concerned: (i) the modifications related to GAEC 1 (19 February 2024); (ii) the revised IACS quality assessment methodology (18 March 2024); (iii) the clarifications on force majeure (9 April 2024); (iv) the simplification of the process to amend CAP Plans 
(9 April 2024); (v) workshop on control rationalisation (26 April 2024); (vi) the clarification note on the use of geotagged photos (15 May 2024); (vii) the revision of the requirement linked to geotagged photos (5 June 2024, 11 July 2024); (viii) the content of the CAP Plans and the provision of information for monitoring and evaluation (5 and 28 June 2024); (ix) control statistics and control data on cross-compliance (28 June 2024, 11 July 2024).

These activities gave the Commission the opportunity to present the context of its proposed measures, to explain the reasons for the relevant modifications or clarifications, and to exchange views with experts and to refine the measures where necessary.

3.3. Gathering further evidence

The simplification package announced two studies. Both are being carried out by contractors engaged by the Commission, and are described below:

Study on simplification and the administrative burden for farmers under the CAP.

This study is examining the complexities that farmers must deal with as regards funding applications, monitoring, checks and environmental/sanitary requirements under the CAP and the associated EU legislation. It takes a four-step approach: (i) a targeted questionnaire to farmers; (ii) follow-up in-depth interviews with 300 selected farmers; (iii) interviews with farmers’ organisations; and (iv) an analysis to disentangle the sources of complexity for farmers between the EU and national levels, and between CAP and other requirements and policies, and to identify areas where the administrative burden can be reduced. The study is expected to be completed by early 2025. It will feed into the reflection on developing and implementing simplification actions.

The Commission made the questionnaire ‘Simplification – the farmers’ point of view’ available in all official languages through the EU survey platform from 7 March until 8 April 2024. It included 23 questions on the profile of the respondents and on issues related to obligations and administrative procedures, particularly as regards applications for CAP support, record keeping and reporting, and on-site checks. Respondents were also asked to suggest ways to simplify the CAP.

Nearly 27 000 replies were received, of which 80% were from farmers who have applied for CAP support, in all Member States. Preliminary results of the closed questions, including an overview of the geographical coverage of the survey, were published in mid-April 2024 16  
( Box 1 ). These preliminary results echo some of the issues raised in the ad hoc consultations with Member States and other stakeholders (see Section 4 and Annex 2). An extensive analysis of the replies, including the open questions, is ongoing, with the results expected by end of 2024. The in-depth interviews with farmers, which took place in spring 2024, will be helpful to understand the rationale and background of the replies provided in the survey.

Box 1: Survey of the administrative burden on farmers - main preliminary findings.

Figure 1 Survey of farmers ‘Simplification – the farmers’ point of view’: perceptions of complexity linked to GAEC standards (% of respondents – farmers applying for CAP support)

Note: Complexity may be linked to understanding, clarity of rules, length of the process, technical difficulties or other issues. Multiple replies where possible including “No opinion” / I did not apply” (i.e. not concerned). Therefore, where respondents indicated that they had no opinion/did not apply the GAEC the other view(s) that they may have expressed on that GAEC standard are not accounted for.

Study on the administrative burden on national authorities and the impact of the ‘new delivery model’ of the CAP.

The study is set to carry out an assessment of the new delivery model (NDM) of the CAP in 2023-2027. It will analyse the extent to which the NDM supports a more results-oriented CAP, strategic planning, and an improvement in the governance system. It will also assess whether the CAP Plan approval process and the safeguards set out in the regulations and procedures ensure that the ambitions of a Member State are proportionate to its needs and to equal treatment of Member States. In addition, the study will examine the burdens and costs that the CAP imposes on administrations at the different stages of implementation (including design, consultation, approval and amendments, setting up and running CAP Plans, enforcement, reporting and evaluation), and the ways to simplify the implementation of the CAP.

This study was launched in August 2024 and its results will feed into the reporting and evaluation deliverables laid down in the CSP Regulation 17 . 

4. OPTIONS CONSIDERED AND THE CHOICE OF INSTRUMENTS FOR THE SELECTED SOLUTION

The suggestions received during the ad hoc consultation process (Section 3.1) fall under the five broad areas presented below. In planning and designing the responses to the suggestions, the Commission took into account: (i) the expectations of farmers and Member States for a simpler and less burdensome CAP; (ii) the necessity to maintain the CAP’s role in supporting the transition of the EU agriculture to sustainable farming; (iii) the nature of the problems identified; and (iv) for legislative matters, the objective to quickly reach an agreement between the European Parliament and the Council, so that farmers could already benefit from some of the changes in 2024. A more detailed assessment of these suggestions is provided in Annex 2.

4.1. CAP strategic plans: management, administration and controls 

This area includes the procedures to amend CAP Plans (including the increase in the maximum number of requests for amendment per calendar year) and the level of detail of the CAP Plans. It also covers elements of the integrated administration and control system (IACS), including the IACS quality assessment methodology, the use of geotagged photos, as well as the control and penalty systems for conditionality and for payments under interventions. Another group of suggestions concerns the simplification of the annual performance review (APR) which is the reporting tool to track the CAP Plan’s performance. Other suggestions concern the CAP’s methods of financing, including to facilitate transfers between the funds. Other suggested changes concern the definitions in the CSP Regulation delimiting CAP support.

In response, the Commission included a few targeted initiatives in the proposal of 15 March amending the EU’s CAP legislation, in particular to enable Member States to submit more requests for amendments of CAP Plans and to eliminate conditionality controls and penalties for small farmers (farms up to 10 hectares). Other actions in the simplification package tackle issues of control burden, such as making the use of geotagged photos under the AMS voluntary (see Section 5.1). The Commission also launched discussions in relation to the requirements of the annual performance clearance.

While those adjustments aim to facilitate processes and the administration of the CAP, the Commission did not consider suggestions that would alter the new delivery model of the CAP more fundamentally. This new system was introduced by the co-legislators only as of claim year 2023, and further experience of its implementation and an assessment of its functioning are necessary. In contrast, a number of other suggestions promoting greater flexibility for Member States can already be addressed within the current legal framework, for example as regards the organisation of controls and the penalty system, including the introduction of a single control of agricultural holdings and the level of sanctions, as long as they comply with the EU requirements. For certain other suggestions, such as the level of detail in the CAP Plans, the lessons learned from the current period will feed into the reflection on the post-2027 CAP and the work on future EU legislation.

4.2. CAP strategic plans: the green architecture

These suggestions concern the various CAP Plan tools to implement the objectives of the CAP in relation to the environment and climate 18 , often together referred to as the ‘green architecture’ of the CAP Strategic Plans. Many suggestions concerned targeted changes to ‘conditionality requirements’ (the basic layer of the ‘green architecture’) but other suggestions were also made, e.g. exempting small and organic farms from conditionality requirements, or changing the financial management of environmental interventions.

As a preliminary step to addressing the concerns underlying these suggestions, the Commission had adopted a temporary and partial derogation from the first requirement of GAEC standard 8 for claim year 2024 (on the share of non-productive areas/features on arable land) 19 , and adjusted the rules for GAEC standard 1 on the calculation of the permanent grassland ratios and reconversion obligations (see Section 5.2) 20 .

Further modifications followed with the amendments to the CSP Regulation and Horizontal Regulation as part of the simplification package. They contained targeted adjustments to conditionality rules that aimed to address implementation concerns for several GAEC standards, and controls and penalties for small farmers (see Sections 5.1 and 5.2).

The Commission opted for this rebalancing in the direction of a more voluntary approach to keep the overall policy objectives supporting the transition to sustainable agriculture and to maintain the set of instruments of the CSP Regulation as decided by the co-legislators in 2021. It considered that, in general, GAEC requirements cover the basic practices backed by the general agronomic consensus and are appropriate to address the relevant needs across all farming systems. Additionally, these requirements mostly prolong or reinforce the requirements that already applied to all farmers before 2023. It is true, however, that some new GAEC standards introduced in 2023 made the conditionality rules much more demanding than in the previous period, or included practices that used to be remunerated under the previous CAP and that have cost implications for farmers’ income.

4.3. Farm income and competitiveness

This area reflects concerns about farm income, with suggestions to: (i) revise the CAP provisions on risk management instruments and to allocate more CAP funds to crisis management; (ii) expand coupled support, or adjust the sectoral support schemes or their financial management; (iii) change the rules on investments; (iv) and take action to improve the position of farmers in the agri-food supply chain.

The Commission shares the concerns related to farm income and proposed measures to improve the position of farmers in the agri-food supply chain and to protect them against unfair trading practices in the separate reflection paper of 15 March 2024. Work is ongoing on putting the ideas in this paper into practice (see Section 5.3).

The Commission is examining the feasibility and the impact of certain limited adjustments to the CAP framework, addressing farmers who are acting together, that could respond to the concerns behind the suggestions received. However, the vast majority of the suggested changes to the CAP would entail fundamental policy changes, and therefore pertain to the reflection on the CAP after 2027. Some suggestions were also not taken up because they were deemed to hamper the achievement of the policy objectives of the CAP Plans. Some suggestions may be covered by the contemplated targeted changes to the Regulation on the common organisation of markets in agricultural products 21 .

4.4. Other CAP instruments

This area covered other elements of the EU CAP legal framework such as postponing or removing social conditionality, and other instruments of the CAP, such as reducing the variables to be collected under the Farm Sustainability Data Network (FSDN), promotion measures, the EU school scheme, marketing standards and organic farming. Other suggestions called for a more fundamental rethink of EU agricultural policy, such as making CAP Plans more strategic.

Many of these suggestions went beyond the remit of simplification and the improved implementation of the CAP Plans. The Commission took the view that the key elements of the CSP Regulation, such as social conditionality should be maintained. The Commission also considered that several suggestions, such as the level of detail on measures required in the CAP Plans, were already feasible within the increased flexibility for the Member States in the new delivery model of the CAP.

4.5. Legislation outside the CAP

The final set of suggestions concerned legislation outside the CAP, in the areas of State aid, environment, animal and plant health, food safety, climate and energy.

In its simplification package the Commission announced a number of targeted changes in acts outside the CAP and is working on non-legislative measures with the aim of simplifying or clarifying certain rules. On 2 May 2024, the Commission also launched the review of the agricultural de minimis Regulation 22 . These rules were last revised in 2019 and were originally set to expire at the end of 2027. Their revision was brought forward and accelerated in light of the inflationary pressure in recent years and the current context with, among other things, high commodity prices affecting the agricultural sector. On 7 June 2024, the Commission launched a public consultation, which ended on 21 July 2024 seeking feedback from stakeholders on its proposal for a draft amendment 23 . For a number of other legislative proposals, policy simplification can still be addressed during the ongoing legislative procedures as explained in Annex 2.

For certain other suggestions, such as the consistency between laws affecting farmers, the lessons learned from the current period will feed into the reflection on the post-2027 CAP and the work on relevant future EU legislation.

Certain comments referred to the ongoing evaluation of the Nitrates Directive and suggestions were made for a temporary exemption that would enable the safe use of RENURE products (recovered nitrogen from manure) in Nitrates Vulnerable Zones beyond the current limit of
170 kg N/ha/year from manure, based on RENURE criteria developed by the Commission’s Joint Research Centre, and which could substitute the use of chemical fertilisers.  Awaiting the outcome of the evaluation, an interim solution that would allow RENURE products to be used  has been prepared by the Commission and, at the time of writing, is pending opinion of the Member States in the Nitrates Committee 24 and the scrutiny of the co-legislators before coming into law. 

5. DESCRIPTION OF THE ACTIONS TAKEN

5.1 CAP Plans: management, administration and controls

Improving the procedure to amend CAP Plans

The handling and management of amendments to CAP Plans is a joint process, requiring a partnership between the Commission and Member States’ administrations to ensure a successful outcome. Building on the experience of the first year of implementation of the CAP Plans, the Commission reviewed the procedure for assessing and approving amendments to CAP Plans.

In its proposal of 15 March 2024, the Commission doubled the maximum number of requests for amendments that Member States may make per calendar year (from one to two) so that Member States can adapt their support measures to changing conditions and farmers’ needs more frequently and in a more targeted way.

On 5 April 2024 the Commission communicated to Member States that it had agreed to streamline the approval process of amendments to CAP Plans and presented the changes on 9 April 2024 25 .  In line with the greater subsidiarity, flexibility, and performance orientation of the 2023-2027 CAP, the Commission services are committed to continue taking a ‘need to know’ approach for the assessment of requests for amendments, and of notifications of changes to rural development interventions 26 :

·The level of detail of the information requested from national authorities will be proportionate to the nature of the modification, focusing on essential and legally required information necessary to understand and assess the proposed changes.

·Where it is obvious from the description of the amendment or change, additional justifications that the change does not affect targets and milestones under the result indicators will not be requested.

·Member States will not be asked to confirm that they respect the EU legal framework where an amendment does not contain any indication of non-compliance.

As regards the Member States, streamlining the approval process will require a realistic planning of requests for amendments, and a clear and focused description of the amendments and accompanying justifications that avoids unnecessary details. Member States are also encouraged to simplify the description of the interventions in their amendments of CAP Plans in the future. An open, constructive, and transparent informal dialogue between the Commission and national authorities, based on advance information on the proposed amendments, helps speed up the approval process. Timely planning of amendments helps manage expectations and avoid unnecessary modification proposals.

Controls for conditionality and cross compliance

Concerns had also been raised about the proportionality and burden of conditionality checks and penalties, especially for smaller farms. The rules on controls of conditionality are laid down in EU legislation, which requires that 1% of farmers must be controlled every year. To address the burden of control in this area, on 15 March 2024 the Commission proposed to exempt small farms of under 10 hectares of agricultural area from controls and penalties related to conditionality requirements. While controls of conditionality no longer apply for these farms, they are not exempted from the conditionality requirements which also continue to be the baseline for other CAP interventions like eco-schemes.

There is a group of beneficiaries under the 2023-2027 CAP who continue to receive area-based rural development support from the pre-2023 CAP. The payments for these voluntary measures are subject to the previous ‘cross-compliance’ system in place in 2014-2022. To reduce the control burden on farmers who are subject to both conditionality and cross-compliance the Commission also proposed on 15 March to exempt these farmers from cross-compliance controls and penalties and to rely solely on conditionality.

Reporting on the results of cross-compliance controls

In line with the Commission’s aim to rationalise and simplify reporting requirements for administrations and given the very limited representativeness of the sample used in reporting on control data and control statistics for cross-compliance, the Commission decided to waive the obligation for Member States to submit these figures for claim years 2023, 2024 and 2025 27 . This modification will apply retroactively from 1 January 2024 to cover the 2023 figures, which Member States were obliged to transmit from 15 July 2024.

Rationalising controls, including the right of error 

The integrated administration and control system (IACS) 28  helps Member States to manage, monitor and control all the area and animal-based CAP interventions, and ensures that comprehensive and comparable EU data is available.

The IACS consists of several elements, integrating information captured, for example, by the Copernicus Sentinel satellites as part of the area monitoring system (AMS) used to observe, track and assess agricultural activities on all hectares claimed under area-based interventions 29 . A key part of the system is the Geo-spatial application (GSA) that allows CAP beneficiaries to visually identify the areas claimed for help in their online aid application. Member States subsequently monitor agricultural activities and check compliance with eligibility conditions using the AMS.

For the relevant interventions, IACS helps Member States to keep track of the performance of the CAP and helps to protect the EU’s financial interests, by helping beneficiaries to make CAP aid applications (applications for CAP support) correctly and by preventing non-compliance with the associated obligations. The IACS contains the necessary data to feed into Member States’ annual performance reports (on the progress in implementing their CAP Plans).

Member States are responsible for setting up management and control systems and decide how often checks should be carried out. The EU-level principles and requirements for these systems are much less detailed than in the previous CAP periods.

To support Member States in rationalising their control systems, the Commission organised a workshop on 26 April 2024 to clarify how the EU-level rules should be applied and to exchange best practices among Member States. These are some of the main issues discussed:

·The Commission reminded Member States that their management and control systems should include the possibility for beneficiaries to amend or correct their aid application or payment claim after submission. Such corrections should be possible until the moment when the applicant is informed that they have been selected for an on-the-spot check, or when the competent authority has taken its decision on the application 30 . 

·Specifically for area-based interventions, Member States are required to inform farmers about non-compliance with eligibility conditions that were detected by the administrative checks or by the AMS. In these cases, farmers are to be given the possibility to amend or withdraw the aid application. To facilitate this further, national authorities may make the necessary corrections in the aid application themselves. In such a case, they must ensure that: (i) the farmers are aware of the changes; and (ii) that they have the possibility to react if they disagree with the change made.

·Combining the use of new technologies with the right of error is helpful in this context as IT systems can automatically inform farmers of potential errors, so they avoid penalties.

·This allows farmers to correct their applications where errors were made or adjust them based on realities on the ground. The goal is to help farmers avoid errors which can lead to non-implementation of the policies. In this way, penalties for farmers are avoided and the policy performance is improved.

·However, controls must remain effective. Therefore, such warning messages cannot be sent after the applicant is informed or made aware of their selection for an on-the-spot check.

The workshop on rationalising controls also enabled Member States to share their experiences in developing management and control systems that alleviate the administration and control burden on farmers without affecting the level of assurance on the outputs declared for performance.

Revision of the EU-level methodology for IACS quality assessment

The main IACS components are subject to an annual quality assessment to evaluate if the IACS is achieving its aims, and to improve how it works (as regards the correct number of hectares for the CAP´s output and result indicators). In this framework, the AMS and GSA quality assessments together provide diagnostic information on the sources of incorrect decisions at the level of interventions and eligibility conditions.

The AMS helps reduce the administrative burden for Member States’ paying agencies and beneficiaries thanks to the automated process. These ensure that applications are correct, as beneficiaries can modify their applications after an early warning alert and encourage farmers to comply with the requirements via a system of pre-warnings to be implemented by the Member States.

In response to Member States’ concerns about the burden of the quality assessment verifications linked to the AMS and the GSA, the Commission revised the EU-level methodology for the IACS quality assessment (published on 21 March 2024).

The revised methodology aims to reduce Member States’ workload by revising the sampling approach, making it possible to group unit amounts among different interventions, and by introducing the possibility to cap at 3% the total number of holdings in the Member State to be included in the quality assessment sample. The sampling procedure was also considerably improved to allow Member States to check multiple parcels on the same holding, so that multiple checks can be carried out during the same field visit. This sampling procedure is similar to the one historically used for the control system, which increases the scope to combine the quality assessment exercise with controls.

Revision of the requirements linked to geotagged photos

The use of geotagged photos was intended to reduce the control burden on farmers. Instead of relying on on-site visits, the farmer provides the authorities with a digital photograph of the geographic position that shows the presence or absence of an activity, or an element that is subject to a legal requirement or is part of the voluntary commitment made by the farmer under the CAP.

According to the EU rules 31 , some eligibility conditions such as nest protection, flower species diversity and animal presence, which can be monitored by the automatic processing of geotagged photos, had to be covered by the AMS by 2027. During the ad hoc consultation, Member States raised several concerns in this regard, such as the development, implementation and optimisation of algorithms to process geotagged photos, the costs of storing them and the shortage of qualified staff. For these reasons, Member States asked for a delay in the introduction of geotagged photos, or that their use should be limited. The survey of farmers also revealed some concerns about their use, which was perceived as an additional burden.

On 2 May 2024, the Commission shared with Member States a clarification note on geotagged photos, which was discussed with Member State experts on 15 May 2024 32 . The note acknowledged the barriers identified by Member States and farmers and aimed to clarify the applicable provisions and outline the benefits of geotagged photos. The note proposed strategies to reduce the administrative burden associated with geotagged photos, including a review of the legal requirements.

Following up, in the CAP Committee of 5 June 2024, the Commission presented a draft amendment of the requirements on the use of geotagged photos to limit the burden on farmers and increase their acceptability and use. The amendment also aims to reduce the burden on Member States by eliminating the requirement to incorporate in the AMS interventions with eligibility conditions that can only be monitored by geotagged photos. Following a positive opinion by Member States in the CAP Committee, the Commission adopted the revised version of the amendment on 4 September 2024 33 .

Given the benefits of geotagged photos, the Commission does not prevent Member States from their usage. The flexible approach ensures that Member States that have already invested in this process will not experience setbacks in their progress and increases the possibilities for a swifter handling of the payment files of farmers who use geotagged photos.

Clarification of the use of the force majeure and exceptional circumstances clause

The concept of force majeure refers to abnormal and unforeseeable circumstances, outside the control of an operator (such as a farmer), the consequences of which could not have been avoided despite taking all due care. Force majeure excuses such a farmer from certain legal consequences that would normally result from non-compliance. The decision to recognise force majeure is taken by the Member State authorities, based on the relevant evidence.

On 30 May 2024 the Commission adopted a Communication to the Council on force majeure and exceptional circumstances 34  in the Horizontal Regulation. The Communication clarifies the application of this concept, focusing on its application based on an area rather than on a case-by-case assessment. This responds to requests from Member States for greater clarity about applying this concept and for greater certainty for farmers as regards their CAP support in such cases.

The Commission has clarified that if severe natural disasters or severe meteorological events, such as flooding or fires, gravely affect a clearly defined area, a Member State may presume that the farmers in the area affected by the abnormal event, whose consequences could not be prevented with all due care, are covered by force majeure. The Member State may make this presumption provided that the determination of the area, of the population of farmers inside it, and where relevant, of the affected CAP obligations, is undertaken in such a way that makes it possible to conclude that the conditions of force majeure are individually met by the farmers concerned.

5.2. CAP Strategic Plans: the green architecture

Conditionality

‘Conditionality’ requires that area- and animal-based CAP payments received by farmers are linked to the respect of certain requirements, including GAEC standards 35  in the areas of climate change, water, soil and biodiversity. These standards are defined in the CAP Plans, based on the framework and main objectives set out in the CSP Regulation.

In 2023, the first year of the current CAP period, farmers encountered difficulties in fully complying with some of these requirements, which had been strengthened compared to the previous period (2014-2022). The measures proposed by the Commission aim to address these challenges in a balanced and targeted way, according to the specificities and objectives of each standard. 

GAEC 1 (Permanent grassland)

GAEC standard 1 requires Member States to maintain permanent grassland based on a (national or regional or individual 36 ) ratio of permanent grassland to agricultural area that is to be compared to the reference year 2018. Where this ratio has decreased by more than 5%,
the Member State is to impose obligations to establish or (re-)convert land into permanent grassland at holding level for some or all of the farmers who have at their disposal areas which had been converted from permanent grassland to other uses. Commission Delegated Regulation 37 lays down the rules to ensure a level playing field when establishing the ratios of permanent grassland in the application of GAEC 1.

The amendment to this Delegated Regulation 38 , published on 26 April 2024, allows Member States to adjust the reference ratio once during the CAP programming period (2023-2027). This may be done to reflect post-2018 reductions in the area of permanent grassland due to structural changes in the farming system, thus substantially impacting the ability of farmers to maintain permanent grasslands while maintaining their farms’ economic viability. When imposing
(re-)conversion obligations on farmers when the ratio fell below 5%, the adjustments also allow Member States to take into account the increase in total agricultural area declared by farmers in their CAP aid application, and areas of permanent grassland that exist 39 but were not declared by them, as well as decreases due to the conversion of permanent grasslands to non-agricultural uses. 

GAEC 6 (Minimum soil cover)

Under GAEC 6 Member States define requirements that ensure a minimum soil cover during the most sensitive periods to avoid bare soil and thus protect it against leaching, erosion and depletion of organic matter. Member States set out in their CAP Plans the most sensitive periods when a minimum soil cover is needed. There is a wide range of different types of minimum soil cover, which mostly includes crops, green cover, stubble, mulching, plant residues or spontaneous vegetation. Sometimes farmers can do shallow tillage to mix the stubble with soil so that the soil stays protected. Some Member States have taken voluntary measures that support the establishment of catch crops and green cover, adding further benefits to the minimum soil cover under GAEC 6. 

The flexibilities in the CAP Plans included e.g. requiring coverage only on 80% of arable land, or specific provisions for heavy clay soil. It is important to note that under this GAEC there were no requirements regarding sowing dates, and that farmers always had the option to plough during the sensitive period if it was for the purpose of sowing in the following weeks. Nevertheless, further flexibility for Member States was considered necessary for a smooth implementation of GAEC 6, taking into account the variety of situations in the field and the contribution of the required practice to the objectives of the GAEC 6 standard.  

Despite the range of possibilities to meet the GAEC 6 standard, in some cases the rules have created practical problems, e.g. where it was impossible to establish and maintain certain soil cover because of the weather situation, creating uncertainty and frustrating farmers.
In particular, when there was late harvesting on heavy soils (often unavoidable in wet autumns), GAEC 6 was seen as an obstacle to autumn ploughing, and forcing farmers to prepare the soil after winter, which entailed, in some cases, a risk of soil compaction.

The Commission proposal of 15 March 2024 to amend the CSP Regulation added the words ‘as determined by Member States’ to the definition of GAEC 6. This clarifies the responsibility of Member States and provides increased flexibility in determining the key elements of this GAEC, in particular the timing and duration of ‘sensitive periods’ for which Member States ‘may in particular take into account the short vegetation period resulting from the length and severity of the winter period in the regions concerned’. However, as specified in recital 15 of the proposal, ‘the Commission should ensure, in accordance with Articles 13(1) and 109(2) and Articles 118 and 119 of that Regulation, that the GAEC standard 6 as determined by the Member States is, overall, in line with the main objective of that GAEC standard’.  

GAEC 7 (Crop rotation/diversification)

GAEC 7 aims to protect soil potential over time through crop rotation. The Commission’s proposal of 15 March 2024 added an option whereby Member States may allow farmers to fulfil GAEC 7 through diversification of crops on their farms within a given year. Certain farming realities and weather conditions can make it difficult for farmers to ensure crop rotation for example market demand for specific crops, seed availability and the windows for sowing certain crops. In 2023, Member States were permitted to grant a derogation from GAEC 7 in light of the impact that Russia’s war of aggression in Ukraine had on global food security. The aim was to ensure that farmers were not prevented from responding to the demand for food crops in line with the changing market context.

GAEC 8 (Non-productive arable land)

GAEC 8, which addresses biodiversity on farms, requires, among other things, that a minimum share of arable land at holding level be devoted to non-productive areas and features (‘the GAEC 8 first requirement’, 4% as a general principle) and that landscape features should be retained. As for GAEC 7, in 2023, Member States could allow farms to derogate from the first requirement of GAEC 8, again because of the impact on global food security of Russia’s war of aggression in Ukraine.

The GAEC 8 first requirement has, however, proved costly for some categories of farmers, particularly in view of the pressure on margins in certain arable crop sectors and in areas with high land prices. Farmers have therefore faced difficulties in complying with this requirement without a direct compensation for the efforts made. The Commission therefore proposed on 15 March 2024 to replace this GAEC 8 requirement with an obligation for Member States to establish an eco-scheme offering support to farmers for the maintenance of non-productive areas, such as land laying fallow, and for the establishment of new landscape features, on arable land.

Member States may decide to remove the first requirement of GAEC 8, as from claim year 2024, if they have an eco-scheme which supports non-productive areas or the establishment of new landscape features, on arable land. Otherwise, Member States must apply this change from claim year 2025 at the latest. 

It is important to have the necessary tools in place to address the objective on biodiversity. Adopting a tool that is voluntary for farmers, and which ensures adequate compensation for the commitment to maintain non-productive areas and establish new landscape features, on arable land, makes the combination of mandatory and voluntary tools better suited to the current context.

Specific exemptions from GAECs 5, 6, 7 and 9 

On 15 March 2024, the Commission also proposed that Member States may provide in their CAP Plans specific exemptions from GAECs 5 (tillage), 6 (soil cover), 7 (crop rotation/ diversification) and 9 (ban on ploughing and converting environmentally sensitive permanent grasslands in Natura 2000 areas) 40  to address specific problems in applying the requirements of those standards so as to ensure the economic viability of farms. These problems could, for example, be due to particular agronomic situations for certain crops in particular soil types and pedoclimatic conditions, or because of the damage to permanent grasslands by wild animals or invasive species. The proposal also laid down that ‘The specific exemptions shall be established only where and to the extent that they are necessary to address specific problems in the application of those standards and shall not significantly hamper the contribution of each of those standards to their main objectives’.

Temporary and targeted derogations from conditionality requirements 

The Commission proposal also contained provisions enabling Member States to introduce temporary and targeted derogations 41 from GAEC standards where, in a given year, farmers would be prevented from complying with them due to weather conditions such as flooding or drought. This possibility can be an important tool to balance the need to apply the GAEC standards as a step in the transition towards more sustainable farming, with the need for flexibility to navigate the changing climate context, which brings increasingly unpredictable weather conditions.

Review of CAP Plans in case of changes to EU environmental and climate legislation

In drawing up their CAP Plans, Member States had to take account of the analysis, objectives and targets of key EU environmental and climate laws (and plans stemming from these) listed in Annex XIII of the CSP Regulation. The CSP Regulation also requires Member States to review and update their CAP Plans when this is necessary to align them to changes in this EU legislation 42 . To avoid frequent changes to the CAP Plans and ensure stability in the support schemes for farmers, the Commission proposal of 15 March 2024 limits the application of this requirement to amendments of legislative acts in Annex XIII that enter into force by 31 December 2025 at the latest.    

5.3 Farm Income and competitiveness

Position of farmers in the agri-food supply chain

The Commission’s paper of 15 March 2024 43  lists several immediate, short-term and medium-term actions to strengthen the position of farmers in the agri-food supply chain, with the ultimate goal of supporting their income and ensuring fair remuneration.

The Commission has already delivered on some of these measures, starting with the set-up of the new EU Agri-Food Chain Observatory (AFCO) 44 . It brings together national authorities and stakeholders representing all levels of the agri-food supply chain with the purpose of promoting increased transparency on prices, the structure of costs and the distribution of margins, as well as added value in the supply chain. The first two meetings of the new AFCO took place on 17 July and 15 October 2024.

In addition, on 23 April 2024 the Commission published a report on the implementation of EU rules against unfair trading practices in the agri-food supply chain 45 . This report takes stock of the implementation of the Unfair Trading Practices (UTP) Directive 46 , and will feed into a more detailed evaluation of the Directive that the Commission will present in 2025. This could be followed, if appropriate, by legislative proposals to revise the Directive. The report is accompanied by a Staff Working Document providing further information, in particular on Member States’ transposition choices 47 .

The Commission is also working on other actions to further correct imbalances in the agri-food supply chain, which includes considering targeted changes to the Regulation establishing a common market organisation of agricultural products (CMO) 48 . This aims to strengthen farmers’ position in the supply chain, including e.g. through improved rules on contracts, a stronger role for producer organisations and their associations, and measures to support voluntary approaches such developing short supply chains and fair-trade schemes. 

The Commission will propose new rules to improve the enforcement of the rules against unfair trading practices for cross border transactions.

5.4 Other CAP instruments

Exchange of best practices 

The Commission organises exchanges between Member States of best practices to simplify interventions and minimise the administrative burden related to the CAP Plans. One of the forums where these exchanges take place is the European CAP Network 49 , which brings together administrators, researchers, entrepreneurs, and practitioners to share knowledge and information about agriculture and rural policy. One of the thematic groups within the CAP Network focuses on designing green strategies under the CAP Plans.

These exchanges serve to identify and share, for example, which elements of the CAP Plans’ green architecture were used and how well they work together. This includes positive experiences and challenges, and the key factors that influenced the design of CAP Plans to address environmental and climate needs. They also serve to explore the different approaches taken with the CAP Plans and how they interact with national funding opportunities.

Support for advisory services 

Knowledge and innovation brought to the field by advisors (for example in the context of the EU Soil Mission 50 ) play a crucial role in helping farmers, foresters and rural communities make the necessary transition to sustainability. If advisory services are poorly organised, insufficiently targeted, or overly bureaucratic, they may present more challenges than solutions. These circumstances may contribute to the low uptake by farmers of measures to improve knowledge and may have an impact, for example, on the rate of adoption of sustainable practices, whether or not supported under the CAP. It is therefore essential that advisory services are impartial, competent, and able to provide well-tailored advice, i.e. they should be easily accessible, respond to the specific needs of farmers and not impose another administrative burden on them.

On 12 April 2024, the Commission sent a note to Member States proposing actions that would encourage them to strengthen the role of advisory services to include and support all impartial advisors, both public and private, and integrate them into their Agricultural Knowledge and Innovation System (AKIS). A national public database of all impartial advisors can provide a transparent overview on which advisors are available, on their experience and education, and their expertise. Such a database gives farmers the freedom to choose their advisor based on objective information and ensures the highest possible impact of the CAP funding invested in providing advice. This approach will help single out the best impartial advisors, who are most appreciated by farmers.

5.5 Elements outside the CAP

Use of remote sensing services according to the proposed Soil Monitoring and Forest Monitoring Laws

In this proposed legislation 51 (the Soil Monitoring Law and the Forest Monitoring Law) the Commission intends to develop and to strengthen remote sensing services in the context of Copernicus. These services could help simplify the monitoring of some of the relevant soil descriptors and make it easier to assess soil health. Earth observation can also improve the efficiency and timeliness of forest monitoring, especially with regard to the health and condition of forests and can help Member States to design and implement measures more efficiently and effectively. 

At the time of writing this document, the proposed Forest Monitoring Law was being discussed by the Council. The proposal aims to: (i) ensure consistent high-quality monitoring that will make it possible to track progress towards achieving EU policy objectives and targets; (ii) improve risk assessment and preparedness; (iii) support evidence-based decision-making by land managers and public authorities; (iv) promote research and innovation.

The trilogues for the Soil Monitoring Law started on 22 October 2024. The proposal aims to put in place a solid and consistent soil monitoring framework for all soils across the EU and to continuously improve soil health with a view to achieving healthy soils by 2050. The proposed Directive therefore lays down measures on monitoring and assessing soil health, sustainable soil management and contaminated sites. The Commission is currently making an inventory of the policy needs for the next Copernicus programme to prepare the next multiannual financial framework (MFF).

Exemption of plant protection products containing only biological active substances from the obligation to keep records

In the context of the study announced in Action 1 of the Communication on Boosting Biotechnology and Biomanufacturing in the EU 52 , which is due to be finalised in mid-2025, the Commission will examine whether to exempt plant protection products containing only biological active substances from the obligation to keep records. This exemption to the obligation under Article 67(1) of the Regulation on placing plant protection products (PPPs) on the market 53 , is aimed at reducing the administrative burden on farmers who use such products. 

Eliminate the requirement that farmers must submit individual applications for aerial spraying of plant protection products once relevant conditions are met 54

The Commission is considering this proposal.

Eliminate the requirement for farmers to keep records of treatment of animals with medicinal products under the Directive on the protection of animals kept for farming purposes 55  

The Commission is considering this proposal.

Evaluation of the Nitrates Directive

An evaluation of the Nitrates Directive 56 (relevant in relation to the SMR 2 conditionality requirement 57 ) is ongoing and included a public consultation. The Commission invited stakeholders to participate in this consultation, also to express their views on the administrative burden under this piece of legislation. The consultation closed on 8 March 2024. The views expressed will be taken into account in the ongoing evaluation.  

In response to requests from Member States and farmers’ organisations, the Commission also presented on 19 April 2024, for public feedback 58 , a draft amendment to Annex III of the Nitrates Directive, which will allow Member States to authorise the use of RENURE fertilisers (i.e. fertilisers derived from manure) by farmers above the limit for manure application in Nitrates Vulnerable Zones, thereby contributing to the replacement of chemical fertilisers. This draft amendment is aimed to be an interim solution to address the immediate needs of farmers while also ensuring appropriate safeguards to comply with environmental protection objectives, particularly the protection of waters against pollution caused by nitrates from agricultural sources. 

Actions in relation to the EU Deforestation Regulation

The EU Deforestation Regulation 59  lays down rules to ensure that certain commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and relevant products are placed or made available on the Union market or exported, only if they are deforestation-free, have been produced in accordance with the relevant legislation of the country of production and covered by a due diligence statement.

To address concerns raised in relation to the Regulation, the Commission put forward a set of measures in its package of 2 October 2024 60 . This includes a proposal for an additional 12-month phasing-in period, which – upon agreement of co-legislators – will shift the date of applicability by 12 months, to allow operators, traders and competent authorities to be better prepared and to fully establish the necessary due diligence systems. In addition, the Commission published a Guidance Document and Frequently Asked Questions (FAQs) which address and clarify many issues raised by farmers and forest owners (see also Annex 2, page 109). 

6. MAIN IMPACTS OF THE SIMPLIFICATION MEASURES

Delivering on its commitment to ease the administrative burden on EU farmers, the Commission listened attentively to the concerns expressed by farmers, their organisations and Member States, and acted on them by delivering concrete measures under the simplification package. They were developed based on suggestions made by and in close cooperation with national administrations and farmers’ representatives. As such, this exercise should contribute to building trust between the different actors and levels of governance, which is an essential factor in better policy delivery. The impact analysis of these measures is summarised
in Annex 3.

6.1 Impacts on the administrative burden for beneficiaries and national administrations

Beneficiaries/farmers

The simplification package is likely to reduce the time that CAP beneficiaries need to dedicate to applications and checks. For some of the measures, quantitative estimates of cost reductions could be made.

Processes can be simplified through the digitalisation of the CAP application procedures (e.g. by using geotagged photos), and the automatic processing of feedback received by farmers from the authorities (early warning notifications under the AMS). The first year of implementation has showed that these solutions have often not been taken up. The actions taken by the Commission (e.g. measures A.4 and A.6 in Annex 1) aim to improve the workability of these solutions, thereby reducing the burden on farmers linked to on-site inspections.
The impact of these actions is difficult to quantify.

The Commission’s clarification of the concept of force majeure (measure A.5 in Annex 1) helps reduce the administrative burden for farmers as it eliminates the need to introduce individual requests, including gathering the evidence and providing it to the authorities. Quantification of the resulting benefits is not possible as it depends on the occurrence of unpredictable events.

The simplification package also streamlines the approach to controls (measures A.3, A.6, B.2 in Annex 1), resulting in fewer on-site visits by the administration, thereby leaving farmers more time to dedicate to their core work.

In particular, the revision of the IACS quality assessment methodology (measure A.3 in Annex 1), should significantly reduce the number of visited farms in the quality assessment sample. It is estimated that the change will reduce the number of visited farms by 50% or more compared to 2023. Assuming a reduction of around 174 000 field visits, this translates to an annual reduction of administrative costs equivalent to EUR 61.8 million for farmers, using average EU values for labour costs. The Commission’s clarifications on the usage of geotagged photos should further reduce the number of on-farm visits and the associated costs.

Farms under 10 hectares of agricultural area represent 65% of CAP beneficiaries. These farms operate on around 9.6% of the EU’s agricultural area and receive around 11% of the EU direct payments (Figure 2). Performing conditionality controls on these farms was thus deemed disproportionate. Their removal (measure B.2 in Annex 1) is estimated to result in approximately 37 600 fewer controls every year. This translates into an annual reduction in the administrative burden of EUR 6.7 million for farmers, based on the average EU values for labour costs. The scope of this modification and, therefore, its economic impact, differs according to the structure of each Member State’s agricultural sector.

It is more difficult to assess time and cost savings for several other actions and depends on how Member States take up the opportunities provided. 

Figure 2 Farms below 10 ha at EU level

Source: DG AGRI, CATS database, data for 27 Member States (2022)

In the absence of data on the number of farmers that benefit from the 2023-2027 CAP and who, at the same time, continue to benefit from rural development support under the 2014-2022 CAP, it is not possible to estimate the costs saved by removing the ‘cross-compliance’ controls (measure B.4 in Annex 1) in such cases.

The reduction of hassle costs and uncertainty for farmers is another important economic effect of the changes brought by the simplification package. Actions which contribute to this include improvements to the early warning systems, the right of error (measure A.6 in Annex 1), and clarification of the concept of force majeure (measure A.5 in Annex 1). 
These actions will help prevent a reduction or withdrawal of CAP support for farmers, which they have already factored in their farm management decision-making process as a source of additional income or to compensate for efforts made for specific practices, thereby preventing possible negative economic impacts if support is foregone. Moreover, these actions also facilitate the handling of aid applications by administrations, thereby reducing the waiting time for the response. The reduction of uncertainty will also have a positive impact on the mental well-being of beneficiaries, by reducing stress (see Section 6.4 on social impacts).  

National administrations

The measures taken will also streamline the processes for national administrations. 

In particular, the simplification package will reduce enforcement costs linked to on-site controls. The revision of the IACS quality assessment methodology (measure A3 in Annex 1) and the removal of controls on conditionality for farms under 10 hectares (measure B.2 in Annex1) are estimated to result in annual cost savings for national administrations of EUR 82.4 million and EUR 13.4 million respectively, using average EU values for labour costs. Further actions contribute to the simplification of controls, such as digitalisation of procedures and the removal of the remaining ‘cross-compliance’ controls (measure B.4 in Annex 1), though these benefits could not be quantified.

Automated IT processes to inform farmers of potential errors in applications will reduce administrative checks by national administrations. Clarification of the concept of force majeure (measure A.5 in Annex 1) eliminates the need for case-by-case assessments by national administrations, where the relevant elements proving the adverse event in an identifiable area have been established. This facilitates a Member State’s response to such disturbances. The streamlined process to approve CSP amendments (measure A.9 and B.5 in Annex 1) and simplified descriptions of interventions will also contribute to lower administrative costs for national administrations.

6.2 Other economic impacts

The package of measures reduces not only costs and risks due to changes in the administrative burden, but also other economic aspects. This is specifically the case for changes to the CAP Plans’ green architecture. Due to difficulties in quantifying the impacts of the changes made to the CAP Plans’ green architecture in many cases, a qualitative assessment is provided.

Changes to the rules under GAEC 1 (permanent grasslands – maintenance of a ratio, measure A.1 in Annex 1) gave Member States the possibility to better integrate structural changes with the needs of farmers to manage their farms in response to market developments. It will be possible for national administrations to react to the effects of such changes in a tailor-made way, while the objective of the standard (climate change mitigation) is respected. More precisely:

·When market developments force farmers to abandon or reduce livestock production and consequently – because the need to feed livestock has been reduced or eliminated – shift production away from grassland and herbaceous fodder towards arable crops, the provisions will allow Member States to adjust the 2018 reference ratio. This should prevent farmers from being required to re-establish permanent grasslands without having livestock, and potentially without an outlet for the fodder produced, if the livestock sector in the region concerned has shrunk. In such cases, the obligation to (re)establish permanent grassland could prevent farmers from maintaining an economically viable activity.

·Member States are also allowed to consider further factors. They can take into account various situations where a reduction in the ratio of permanent grassland does not result from farmers converting permanent grassland to other agricultural uses, and where it would therefore be disproportionate to ask farmers to re-establish areas of permanent grassland. Such situations include, for instance, the case where the change in the ratio results from an increase in the total agricultural area. Member States also have, for instance, the possibility to take into account the existence of non-declared permanent grassland.

The adjustments to GAEC 6 (soil cover, measure B.1 in Annex 1) provide greater flexibility to Member States, in particular to define the sensitive period during which soils should be covered. This can give farmers greater flexibility in organising soil preparation and can reduce the constraints and the related financial risks. How Member States will use this adjustment remains largely unknown at this stage, although the Commission has already received several requests to shorten the sensitive periods. At the same time, it remains essential that the adjusted requirements in the CAP Plans keep contributing to the main objective of the standard as poor soil quality can seriously affect agricultural production, including resilience and productivity, resulting in economic losses.

The existing flexibilities under GAEC 7 ensure a system of crop rotation on all parcels of land over several years, which is suitable for all the main types of farming, and which avoids unnecessary rigidities. The option of a yearly diversification of crops (measure B.1 in Annex 1) provides further flexibility for managing parcel allocation. This can be useful for some farming systems, and the actual situation on farms, by reducing uncertainty costs while still serving the objective of preserving soil potential, and thus also the productivity of the land.

It is difficult to make an assessment of the impact (both economic and environmental, see Section 6.3) of removing the GAEC 8 first requirement (the share of non-productive areas and features, measure B.1 in Annex 1) due to: (i) the lack of reference data on the implementation of that requirement; (ii) the lack of information on the extent to which farmers would declare existing landscape features or fallow land to fulfil the requirement;
(iii) the future coverage (Member States are not obliged to have interventions with the same scope as the deleted GAEC 8 requirement), uptake and impact of the eco-scheme to be created by Member States to replace this GAEC 8 requirement (see also Section 6.3).

Notwithstanding these constraints, the estimate made by the Commission’s Joint Research Centre through the ‘Individual Farm Model for Common Agricultural Policy Analysis (IFM-CAP) 61  and based on data from the Farm Accountancy Data Network (FADN), provides some indications of additional income for farmers as a result of this change. The approach taken in this modelling exercise is explained in Annex 4.

According to these estimates, lifting this GAEC 8 requirement will impact roughly 1.1 million farms, covering approximately 76 million hectares of arable land, by potentially freeing for production close to 2.1 million hectares of ‘GAEC 8 non-productive land’. That is the area which, in the absence of the adjustments, would have been dedicated to additional fallow-land or landscape features such as woody elements or grass strips. At the EU level, the economic impact measured as the annual change in the gross margin of arable crops (additional income/avoided income loss) is estimated to be around EUR 930 million. This corresponds to a 1.5% increase in gross margin for the impacted farms, though this may differ at more disaggregated level, such as according to the economic size of the farms or the type of production.

Another insight comes from the uptake of the 2023 derogations from this GAEC 8 requirement, with significant variations across Member States in terms of land taken up for production. This uptake resulted in the cultivation of cereals and, to a lesser extent, dry pulses and leguminous crops, rapeseed, sunflower and potatoes, generating additional income opportunities. Differences in the quality of fallow land to produce crops, in the size and location of the fallow land, and in the existence and attractiveness of voluntary measures influenced land use in that year. This provides a good indication for what is likely to occur.

At the same time, the economic benefits of additional landscape features and of fallow land on arable farms should not be neglected, given their benefits for the farms’ resilience, the overall stability of crop production and agricultural productivity in the medium and long term through eco-system benefits in relation to water retention and quality, pest control and the prevention of soil erosion.

The IFM-CAP calculations do not consider the introduction of eco-schemes for the maintenance of non-productive areas and for the establishment of new landscape features that Member States are required to set up in compensation for removing the GAEC 8 first requirement. As these eco-schemes are voluntary for farmers, it can be assumed that farmers will engage only where the compensation offered will surpass their extra costs. This could be particularly attractive for farmers who already have fallow land or marginal and low productive arable land, where the commitment to leave it non-productive implies a limited opportunity cost and less attractive for more intensive farms. Also, farmers with more productive arable land could enter a voluntary commitment, given the financial compensation and the advantages that the presence of non-productive areas create for the holding’s long-term productivity.

Leeway granted to Member States to set out in their CAP Plans targeted and duly justified exemptions from the requirements under GAECs 5, 6, 7 and 9, or to grant time-limited derogations to help tackle the effects of unexpected weather events (measure B.1 in Annex 1), can reduce specific structural or meteorological obstacles for farmers. While the scope of both facilities should be limited (in terms of areas and farmers), they might have important positive economic effects or limit possible negative economic consequences for the farmers concerned. In the case of GAEC 7, an example could be parcels used to produce certified seeds. Imposing crop rotation would be disproportionate as it would make it significantly more difficult to fulfil the specific requirements for producing certified seeds, with an impact on the potential revenue related to such production.

6.3 Environmental impacts

Administrative measures such as improved monitoring, the uptake of geotagging and early warning, the better design of CAP interventions and improved access to advice (measures A.4, A.6, A.7 and A.8 in Annex 1) help farmers to adjust farm management practices in a timely manner where needed, thus ensuring that there are benefits for the environment and climate. This contributes not only to better environmental outcomes for mandatory practices but also makes it more likely that farmers make these voluntary commitments in the future. For this reason, the potential environmental impact of these measures is considered to be generally positive.

Assessing the impact of lifting the conditionality controls and penalties on smaller farms (measure B.2 in Annex 1) needs to be nuanced and cannot be properly assessed at this stage due to its novelty. First, these farms are not exempt from conditionality requirements under the CAP, nor under the relevant EU law in case of the SMRs 62 . Secondly, voluntary commitments have conditionality as a baseline and the practices to which farmers subscribe should go beyond the conditionality. Therefore, small farms participating in voluntary CAP interventions, for example eco-schemes, will inherently have to fulfil the related conditionality requirements, particularly GAEC standard(s) that are part of the baseline for these interventions. Thirdly, due to the relatively small agricultural surface managed by small farmers (accounting for around 9.6% of the EU’s total agricultural area), any potential non-compliance should not significantly hamper the objectives of these GAEC standards. The impact differs between Member States because of the significant differences in the share of smaller farms. 

Changes to the delegated legislation on the ratio of permanent grassland under GAEC 1 (measure A.1 in Annex 1) are not expected to affect its main objective to be a ‘general safeguard against conversion to other agricultural uses to preserve carbon stock’ with only a modest impact on the entirety of the carbon stock. The flexibility granted to Member States will not incentivise the conversion of permanent grassland but will make it possible to take into account significant structural developments in a strictly defined way, and gives Member States the option to consider a more nuanced implementation of the requirement.

The modifications of the CSP Regulation provide that exemptions to GAEC 5 (tillage), GAEC 6 (soil cover), GAEC 7 (crop rotation/crop diversification) and GAEC 9 (environmentally sensitive permanent grasslands) (measure B.1 in Annex 1) shall be targeted in a way that ensures that the exemption will not significantly hamper the main objectives of these GAEC standards, and hence they should not significantly affect the environmental impacts of the CAP plans.

By making it possible to take greater account of the diverse and sometimes complex nature of farming and of factors affecting the impact of certain practices on the environment 
(e.g. the characteristics of specific types of production, farming systems, types of soil, crops and/or Member States’ pedoclimatic conditions), these requirements can be designed to limit the potential environmental drawbacks of otherwise good practices. For instance, in the case of GAEC 6, the characteristics of heavy clay soil can be such that the benefits of ensuring a full minimum soil cover over winter need to be balanced against the risk of compaction posed by preparing the soil for sowing in early spring. Similarly, the use of mechanical weeding under organic farming may make it necessary to prepare the soil at an early stage. When considering such exemptions it is, however, important to also keep in mind the long-term impact of certain practices on the objectives of the GAEC standard and give value to the range of different farming practices that exist.

The main requirement for farmers set out across all CAP Plans under GAEC 9 (environmentally sensitive permanent grasslands in Natura 2000 areas) entails a ban on the conversion and ploughing up of these grasslands. This is a continuation of the greening rules that applied during the pre-2023 CAP period. The amendments brought by the Commission’s proposal of 15 March 2024 to allow targeted exemptions ensure, in particular, that where the grass cover has been destroyed (e.g. due to damage made by wild animals or invasive species), the necessary tillage can be carried out to restore the grassland. This reflects both agronomic and biodiversity considerations for the renewal and regeneration of such grasslands, though the actual impact of this flexibility will depend on Member States’ implementation choices. If applied properly this flexibility should not, in principle, substantially affect the contribution of this requirement to the standard’s biodiversity objective.

The possibility to grant temporary derogations (measure B.1 in Annex 1) will enable Member States to address the consequences of increasingly unpredictable weather events, such as the drought episodes and rainfalls of autumn 2023. As this concerns situations where farmers are prevented from respecting GAEC requirements, such temporary derogations should have a neutral effect on the environment. In some cases, the derogations should also serve the purpose of avoiding counterproductive consequences for farmers aiming to satisfy GAEC requirements against what is agronomically practicable.

It follows that, overall, these amendments to the CAP framework (targeted exemptions and temporary derogations) are expected to have a limited environmental impact, if applied properly, since they are tools to address specific situations and problems without substantially changing basic practices.

As regards GAEC 6 (minimum soil cover, measure B.1 in Annex 1), while in many cases the main objective of this GAEC (the protection of soil against erosion) is further supported by voluntary commitments relating to e.g. green cover, catch crops and enhanced crop rotation or diversification, the overall impact will depend on the scope and uptake of these commitments.

Crop diversification, as an alternative to crop rotation under GAEC 7 (measure B.1 in Annex 1) provides farmers with an extra choice but maintains its role in helping to make farming systems more resilient. With crop rotation, farmers change the crops grown on each parcel from one or more year(s) to another. This limits the depletion of soil nutrients and
the spread of pathogens. Despite the requirement to have at least two or three different crops on a farm in any given year, crop diversification might not guarantee a similar change in crops on land over time. While this might not bring the full environmental benefits of crop rotation, one of the purposes of crop diversification is to prevent a generalisation of monoculture which could be happening in some arable areas due to structural changes. It also indirectly encourages rotation, as once farmers are obliged to have different crops, it makes sense agronomically to alternate them in the fields in the following year.

The environmental impacts of the change to GAEC 7 will depend on the level of diversity that will be required, especially the number and type of crops (e.g. leguminous crops), the share of different crops as well as the crop definition for this purpose, and then the extent to which farmers will choose this option. Allowing a high proportion of the land to be allocated for the main crop in diversification may imply a more static situation with fewer environmental benefits. To prevent this, the Commission proposal incorporates minimum requirements identical to the ones set under the greening scheme in the pre-2023 CAP (based on the requirement to have three crops, with a maximum of 75% coverage for the main crop).

The greening scheme’s experience of the crop diversification requirement showed that while it had a limited influence over the cropping patterns at macro level it increased diversification of certain farms. This is particularly true in areas with high levels of monocropping, by replacing maize or other cereals with crops that provide better soil cover (which improves soil structure) like legumes or fallow land. This requirement also encouraged  rotation 63 .

As the most plausible scenario, a return to practice of diversification of crops could occur in most Member States, but farmers will continue to have the choice to fulfil the GAEC standard through rotation. Also in this case, the contribution of the CAP Plans will heavily depend on their articulation with voluntary commitments that go beyond GAEC 7.

The fundamental change in the simplification package concerns GAEC 8 (measure B.1 in Annex 1). The core new and strengthened requirement, compared to the pre-2023 CAP, was the share of arable land to be devoted to non-productive areas and elements at farm level (4%, and in some cases 3%). The assessment of the environmental impact of removing this obligation is constrained in particular by the lack of experience of full implementation (see also the previous section). Its replacement with a compulsory eco-scheme to improve on-farm biodiversity through incentives can only be assessed when the design and the level of uptake by farmers of these new eco-schemes becomes known. Furthermore, many CAP Plans include voluntary interventions that build on the first requirement of GAEC 8, in term of quality and/or quantity, and those might also be revised. With the removal of the obligation, it is likely that the total size of non-productive areas and features on arable land will decrease due to economic pressures.

The best available reference figures to support an assessment come from the FADN records for fallow land (see also Section 6.2 above), the LUCAS (land use/land cover) survey for landscape features, and, as regards the areas covered by the first requirement of GAEC 8, from implementation of the obligation in the pre-2023 CAP to create Ecological Focus Areas (EFAs). However, productive areas such as catch crops, nitrogen-fixing crops and short-rotation coppices were also permitted under this EFA obligation.

At macro level (EU, Member States), the deletion of the first requirement of GAEC 8 on non-productive elements (areas and features) is not expected to entail an equivalent reduction in the arable land devoted to non-productive areas and features. GAEC 8 maintains a requirement to protect existing landscape features, and a certain level of fallow land will still be kept for agronomic purposes (‘voluntary fallow’).

Furthermore, the 2022 LUCAS survey determined that woody, grassy, wet and stony elements comprised an average of 4.9 % of EU arable land, ranging from 3% to 9% at the level of Member States. At the level of EU agricultural land this share is 5.6% (Figure 3). However, not all of these elements may have been within the scope of the GAEC 8 retention requirement and, therefore, were not declared under the EFA. The estimates based on the FADN data indicate that at least 1.2 million hectares under the CAP would remain fallow in the absence of the GAEC 8 requirement.

Figure 3 Share of landscape features on agricultural land at NUTS 2 level (CAP impact indicator I.21)

Source: JRC, more at : https://publications.jrc.ec.europa.eu/repository/handle/JRC136069

There are certainly significant differences between farming systems and farm locations. There is an unequal distribution of fallow land and landscape features among farms. As a consequence, it is expected that the impact of the removal of the GAEC 8 first requirement on biodiversity will be seen in regions with few landscape features and highly productive arable land, which are then also less likely to commit to voluntary measures. The literature review has shown the benefits of a wide distribution of non-productive elements across holding parcels as regards ecosystem services. These benefits include: (i) the limiting of erosion thanks to the effect of hedgerows on improved soil quality; (ii) the effect of windbreaks on microclimates; (iii) a reduction in diffuse pollution by nitrates and phosphates; (iv) a reduced use of plant protection products; (v) increased pollination and (vi) greater control of crop pests. However, these benefits may not materialise for the farming systems characterised by few landscape features and highly productive arable land.

While GAEC 8 aims to improve biodiversity on farms, there are other environmental effects linked to non-productive areas given that, in general, they are free from fertilisers and plant protection products. Based on the estimates on the economic impacts calculated using the IFM-CAP model (Annex 4), the quantity of nitrogen mineral-fertiliser used in relation to the deletion of the GAEC 8 first requirement could increase by around 9.5 million tonnes (+2.1%) for the impacted farms. The increase in annual greenhouse gas emissions due to mineral fertilisation is estimated to be in the range of 900 kt CO₂ equivalent (+0.21%) for the impacted farms (compared to the situation with GAEC 8, first requirement). These figures do not represent actual increases in most Member States, as the GAEC 8 first requirement was not applied in many countries in 2023. So, these figures rather represent the absence of a decrease that could have happened due to the GAEC 8 first requirement. The figures cover the estimated use of mineral fertilisers on the 2.1 million hectares of arable land concerned. Other environmental impacts, in particular on biodiversity, could not be quantitatively assessed at the time of writing by using IFM-CAP.

6.4 Social impacts

Farmer communities tend to perceive the control and penalty systems negatively, as being disproportionately focused on and penalising minor or incomprehensible non-compliances.

With better use of the tools that Member States have at their disposal during the 2023-2027 CAP and with adjustments brought by the simplification package, farmers’ applications for CAP support can be completed more easily and then, if necessary, corrected in time so that eventual penalties may be avoided (measures A.6 and A.7 in Annex 1). There should also be fewer on-site checks and a more straightforward treatment of force majeure cases (measures A.3, A.5, A.6, B.2 and B.4 in Annex 1). These changes should not only simplify farmers' administrative tasks, but also reduce stress factors. Similarly, the increased flexibility and removal of certain restrictions on farm management (measure B.1 in Annex 1), should simplify their daily work and reduce the incomprehension and frustration linked to what farmers perceive as interference in farm management in opposition to the agronomic reality, and for which they see no direct economic benefits.

The advisory services have an essential role, particularly for small and medium-sized farms, when introducing new technologies and innovative solutions. Due to limited resources and technical knowledge, those farmers often have more difficulty in implementing modern agricultural practices and making their farms more competitive. Improving the availability of independent and targeted quality advice (measure A.8 in Annex 1) will have significant and positive effects on the number of skilled people employed and on the management of farms, considering their specific needs, including as regards more sustainable farming, thus promoting the CAP’s environmental and climate objectives.

6.5 Impacts relating to the performance, monitoring and evaluation framework

The orientation on results as well as the increased flexibility in the new delivery model of the CAP, based on CAP plans, relies upon a robust performance, monitoring and evaluation framework (PMEF). The simplification changes made to existing legislation, and other accompanying actions, therefore also require modifications of certain elements of the PMEF set out in the CAP Plans: indicators, unit amounts, financial allocation and reporting.

When designing the PMEF, improved conditionality (including the first requirement of GAEC 8) has been treated as the baseline, i.e. the level of environmental improvements to be reached by all EU farmers receiving CAP support. Thus, area-based result indicators relate only to the voluntary commitments that go beyond these mandatory practices. Removing the GAEC 8 first requirement and replacing it with new voluntary commitments (measure B.1 in
Annex 1) implies that the values that result indicators should reach for the share of areas under these commitments (such as R.31 Preserving habitats and species and R.34 Preserving landscape features) would normally be higher (since areas under the GAEC 8 first requirement were not considered in these indicators), though this does not necessarily lead to greater impacts.

Several interventions (mainly eco-schemes and agri-environment-climate commitments) that build on the GAEC 8 first requirement 64 are also impacted. When designing these interventions, Member States could not take into account the hectares needed to comply with the GAEC 8 first requirement. Following the removal of this requirement, Member States will have
the possibility to take these hectares into account in the payments of the interventions
to cover the related costs. This could lead to a higher uptake and, therefore, to higher outputs and higher values under the relevant result indicators.

Finally, to incorporate new eco-schemes in their CAP Plans or to increase the unit amounts of eco-schemes or other interventions, Member States will need to revise their CAP Plans, which may require them to reassess priorities and reallocate the current financial allocations, leading potentially to a reduction in the planned outputs for other interventions and
in the relevant result indicators.

All these changes will require CAP Plan amendments before the start of the 2025 claim year.

Monitoring

The need to collect information on the temporary derogations from GAECs and the eco-schemes introduced in connection with deleting the GAEC 8 first requirement (measure B.1 in Annex 1) required changes in the related secondary EU legislation 65 as regards the evaluation of the CAP Plans and the provision of information for monitoring and evaluation. The amendment to this legislation was supported by a large majority of Member States 66  and the Commission adopted it on 18 July 2024 67 . 

For the eco-schemes, two additional variables for the area of arable land supported (for non-productive areas and for the establishment of new landscape features) will need to be reported by Member States, as the current system provides only for reporting on the total area supported (including permanent grassland and permanent crops potentially eligible for the eco-scheme). The data collection is already in place, as Member States had implemented it to monitor the GAEC 8 first requirement. The changes are limited to ensure consistency with the basic CAP legislation and to follow the implementation of the simplification measures in 2024.  In addition, due to the deletion of the first requirement of GAEC 8 certain beneficiary variables will become redundant and, therefore, will be deleted from claim year 2025 onwards.

In addition, the application of the temporary derogations from GAECs should be reported by Member States 68 . This is important for the Commission to be aware of the frequency or extent of these derogations, given their potential impact on the objectives of the CAP and to ensure the integrity of the policy. However, this does not entail an additional burden for farmers, as Member States will report the content, duration and scope of the derogations, and not which farmers applied the derogation and on how many hectares.

Changes to the other GAECs do not require any further modification of the EU implementing legislation for data on interventions and beneficiaries 69 .

Evaluation

The evaluation of the CAP is not influenced. While the adjustments in the implementation of the policy will be taken into account, including derogations and exemptions to certain GAECs, the overall content and approach will not be affected. The timing of the delivery of the evaluation reports, be it the interim evaluation or the ex-post evaluation 70 is not concerned by the proposed actions.

7. CONCLUSIONS

The co-legislators modernised the CAP for the 2023-2027 period, to better address societal concerns about sustainable farming as well as to increase the efficiency of the policy through a new delivery model.

The policy’s novel approach, with performance-oriented CAP Plans and the increased level of ambition, demanded greater efforts and resulted in a steep learning curve for both farmers and national administrations. This policy shift took place in the context of the Commission’s ambitious Green Deal agenda and Green Deal legislative proposals, which will or may affect farmers both directly and through the requirements set out in the CAP Plans. Other significant factors were the considerable market disturbances due to the COVID-19 pandemic, and Russia’s war of aggression against Ukraine, which led to a significant increase of farmers’ costs and caused some farming families anxiety about their livelihoods. As the new policy was rolled out in 2023, these concerns found an outlet in the farmers’ wide-scale protests of early 2024, highlighting their concerns about EU policies.

For this reason, the Commission decided to act immediately. In its brief consultation linked to this process, the Commission received over three hundred different simplification suggestions from EU farming organisations, Member States and the Committee on Agriculture and Rural Development of the European Parliament. They cover a broad range of policy, implementation, organisation, and economic issues, and demonstrate the need to clarify the existing rules.

The Commission carefully examined these suggestions, the provided explanations, and other feedback when proposing its simplification package of 22 February 2024, having weighed up the advantages and disadvantages of various options. The Commission maintained the overall orientation and ambition of the 2023-2027 CAP to steer the transition to sustainable and resilient farming, without generating unnecessary and disproportionate burdens on farmers and taking account of the sector’s recent experience with implementing the CAP. This approach focused on solutions that immediately tackle farmers’ concerns, that better equip national administrations to support and guide farmers in the necessary transition, and that help regain farmers’ trust.

The resulting initiative consists of various EU legislative and non-legislative measures aiming to tackle these complex issues, and with only targeted changes to the policy framework to preserve its level of ambition but provide greater flexibility. The Commission also promotes better communication, peer exchange and guidance.

It is expected that the simplification package should help reduce paperwork, gain time, and increase flexibility in how farms are managed. This should lead to positive effects not only on farmers’ finances but also on their well-being with fewer stress factors linked to the complexity of the rules, set against the day-to-day reality of farming. Better feedback on fulfilling the conditions for CAP support, and more workable monitoring and controls should further help in rebuilding trust and acceptance of the CAP requirements. Changes in the control approach alone are expected to bring at least EUR 164 million worth of savings linked to the reduced time and effort expended by farmers and national administrations. These resources could be dedicated, for example, to improving communication, knowledge and advice.

These changes also reflect the fact that the cost of the transition is significant and requires support. The economic impact of complying with the first requirement of GAEC 8 alone is estimated to be around EUR 930 million annually. The policy mix was thus rebalanced and moved away from obligations towards incentives. This replacement of GAEC 8 first requirement with a voluntary eco-scheme aims to create areas for biodiversity in a way that takes account of farmers’ concerns and compensates them for the efforts they make, mitigating the negative impact of ending the obligation. Providing advice, and a customised policy approach, remain of utmost importance. Making requirements better adapted to specific sites should improve farmers’ understanding and acceptance of the environmental objectives of the policy and improve the environmental outcomes by avoiding counterproductive practices.

A variety of suggestions raised in consultation submissions can already be addressed under the current CAP framework. Member States play a key role in reducing administrative burdens and are encouraged to take advantage of the increased flexibility they now have.
The Commission will continue to assist them and help them to learn from each other to build confidence and avoid situations where fear of the consequences of misapplying the rules lowers the ambition of their CAP Plans. This should also help them to better accommodate increasingly unpredictable weather conditions and capitalise on the benefits of digital technology for policy monitoring and improvement. 

In the immediate term, certain reprioritisation and/or financial adjustments of their CAP Plans will be necessary to back up the flexibilities in the green architecture.

The Commission will work on completing the implementation of the simplification measures. Other actions to reduce the administrative burden are under way for 2024 and beyond and include reducing reporting obligations, while the outcomes of studies on the administrative burden and the new delivery model will help identify further actions to simplify policies for farmers. The parallel workstream to improve the position of farmers in the agri-food supply chain is also ongoing, to address the broader issues of farmers’ remuneration.

Numerous other suggestions from the consultation were not taken up, so as not to change the fundamental elements of the 2023-2027 CAP. These ideas, as well as lessons learned from the implementation of the policy, will feed into the reflection on a wider policy review for the post-2027 period, as will the outcome of the Strategic Dialogue on the Future of EU farming.

ANNEXES

Annex 1: Actions announced by the Commission on 22 February 2024 (the simplification package) and their delivery.

Annex 2. Overview of the simplification suggestions received

This is not a legally binding document. It was prepared by the departments of the Commission and does not commit the European Commission. The explanations, which are part of the assessments of the simplification suggestions submitted by Member States and stakeholders in respect of certain EU legal acts are provided for information purposes only. In the event of a dispute involving EU law, under the Treaty on the Functioning of the European Union, it is ultimately for the Court of Justice of the European Union to provide a definitive interpretation of the applicable EU law.

I. CAP STRATEGIC PLANS – MINIMUM REQUIREMENTS, FINANCING, MANAGEMENT, PERFORMANCE