Special Report The Land Parcel 
Identification System: 
a useful tool to determine 
the eligibility of 
agricultural land – but its 
management could be 
further improvedEN 2016  NO 25
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The Land Parcel 
Identification System: 
a useful tool to determine 
the eligibility of 
agricultural land – but its 
management could be 
further improved
(pursuant to Article 287(4), second subparagraph, TFEU)Special ReportEN 2016  NO 25
02
 Audit team
The ECA’s special reports set out the results of its performance and compliance audits of specific budgetary areas or 
management topics. The ECA selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming developments and political 
and public interest.
This performance audit was produced by Audit Chamber I — headed by ECA Member Phil Wynn Owen — which 
specialises in sustainable use of natural resources. The audit was led by ECA Member Nikolaos Milionis, supported 
by Ioulia Papatheodorou, head of private office; Kristian Sniter, private office attaché; Helder Faria Viegas, principal 
manager; Jan Huth, head of task, and Ramona Bortnowschi, deputy head of task. The audit team consisted of Marius 
Cerchez, Jindrich Dolezal, Blanka Happach, Christine Kleinsasser, Sven Kölling, Ioannis Papadakis, Roberto Resegotti, 
Bruno Scheckenbach and Maciej Szymura, auditors. Language support was provided by Tom Everett and Michael 
Pyper; secretarial assistance by Monika Schmidt.
From left to right:  I. Papadakis, I. Papatheodorou, H. Faria Viegas, N. Milionis, M. Szymura, J. Huth,  
K. Sniter, R. Bortnowschi, R. Resegotti.
03
 Contents
Paragraph
 Glossary
I-IV Executive summary
1-7 Introduction
1-3 Background
4-7 LPIS specifications
8-12  Audit scope, objectives and approach
13-33  Part I – Despite good achievements in the implementation of the Land Parcel 
Identification Systems, room for improvement remains
14-15  Good achievements in the implementation of the LPISs
16-20  Ortho‑imagery was mostly up‑to‑date
21-25  Photo‑interpretation was not always reliable or conclusive
26-28  Pro‑rata was not always applied reliably
29 Semi‑automated detection tools were being tested, but were not yet operational
30-31  Information on whether the land is actually at the farmer’s disposal was included in some LPISs
32-33  Insufficient information for fully assessing the cost‑effectiveness of implementing the LPIS
34-55  Part II – The Land Parcel Identification System was being upgraded to meet the 
requirements of the CAP reform
35-43  The adaptation of LPISs by Member States for greening was progressing but was not yet complete
44-55  Simplification is ongoing but remains a challenge
04 Contents 
56-72  Part III – The Commission’s LPIS monitoring improved but did not focus enough 
on LPIS performance
57-59  The Commission’s LPIS‑related guidance improved compared to the previous CAP period
60-64 Action plans and financial corrections addressed LPIS shortcomings
65-69  The reliability of the LPIS quality assessment results was undermined by the weaknesses in its 
methodology and application
70-72  The QA results were not sufficiently used to improve the quality of the data in LPIS
73-80  Conclusions and recommendations
 Annex I — LPIS layers as indicated in Article 5(1) and 5(2) of Regulation (EU) No 640/2014
 Annex II — QA exercise 2015 – QEs by conformance class
 Reply of the Commission
05
 Glossary
Administrative checks : Formalised and automated checks carried out by paying agencies on all applications in 
order to verify eligibility and detect any irregularities.
Agricultural activity : (i) Production, rearing or growing of agricultural products and keeping animals for farming 
purposes, (ii) maintaining an agricultural area in a state which makes it suitable for grazing or cultivation or (iii) 
carrying out a minimum activity, as defined by Member States, on agricultural areas naturally kept in a state suitable 
for grazing or cultivation.
Agri‑environment‑climate measures : Agri‑environment‑climate measures are among the most important rural 
development measures in terms of financial allocation from the European Agricultural Fund for Rural Development 
and are aimed at delivering environmental and climate‑related public benefits.
Agricultural area : Any area taken up by arable land, permanent grassland and permanent pasture, or permanent 
crops.
Agricultural parcel : A continuous area of land, declared by one farmer, which includes no more than one crop 
group.
Basic Payment Scheme (BPS) : Agricultural scheme operated on the basis of payment entitlements allocated to 
farmers in the first year of application of the scheme and activated each year by farmers.
Cross‑compliance : A mechanism that obliges farmers, in order to receive the full amount of payments, to respect 
a set of basic rules on environmental, public and animal health, animal welfare and/or land management.
Declared area : Total area declared (by all farmers) on a reference parcel and used for further processing by the 
paying agency.
Ecological Focus Area (EFA) : Area designated pursuant to Article 46 of Regulation (EU) No 1307/20131 to bring 
about benefits for the environment, improve biodiversity and maintain attractive landscapes. EFAs may include 
landscape features, buffer strips, afforested areas, fallow land, areas with nitrogen‑fixing crops etc.
Estimated level of error : Our annual best estimate of the error affecting a class of payments. It is calculated based 
on the results of tests carried out on a representative sample of transactions. It is expressed as a percentage of 
erroneous payments in the total value of payments. This percentage lies, with 95 % probability, within a confidence 
interval defined by a lower and an upper limit.
European Agricultural Guarantee Fund (EAGF) : This fund provides funding for direct payments to farmers, the 
management of agricultural markets and a number of other purposes, such as veterinary and plant health measures, 
food programmes and information activities.
European Commission’s Directorate‑General for Agriculture and Rural Development (DG Agriculture and 
Rural Development) : DG Agriculture and Rural Development is responsible for implementing agriculture and rural 
development policy including farm support, market measures, rural development, quality policy, financial and legal 
matters, analysis and evaluation, and for international relations relating to agriculture.
1 Regulation (EU) No 1307/2013 of the European Parliament and of the Council of 17 December 2013 establishing rules for direct payments to farmers 
under support schemes within the framework of the common agricultural policy and repealing Council Regulation (EC) No 637/2008 and Council 
Regulation (EC) No 73/2009 (OJ L 347, 20.12.2013, p. 608).
06 Glossary 
European Commission’s Joint Research Centre (JRC) : The European Commission’s in‑house science service which 
employs scientists to carry out research and provide independent scientific advice and support for EU policy. The 
‘MARS unit’ within the JRC develops and updates the quality assessment (QA) methodology.
Executable Test Suite (ETS) : A collection of test cases (the quality elements) that are intended to be used to test 
the LPIS to show that it has a specified set of behaviours.
Field visits : Ad‑hoc visits to the field undertaken as part of an LPIS update or QA for clarification where picture 
interpretation is not sufficient to assess the extent to which a reference parcel is eligible.
Geospatial aid application (GSAA) : A pre‑established aid application form and the corresponding graphic material 
for farmers, provided through a computerised geographical information‑based interface as referred to Article 72(3) 
of Regulation (EU) No 1306/20132, which is used for processing spatial and alphanumerical data on areas declared.
Grasses or other herbaceous forage : All herbaceous plants traditionally found in natural pastures or normally 
included in mixtures of seeds for pastures or meadows in the relevant Member State, regardless of whether or not 
these are used for grazing animals.
Integrated Administration and Control System (IACS) : An integrated system that consists of databases of 
holdings, applications, agricultural areas and payment entitlements (in those Member States applying the Single 
Payment Scheme). These databases are used for administrative cross‑checks on all aid applications for most EAGF 
measures (e.g. single payment scheme, single area payment scheme or other direct payments).
Land Parcel Identification System (LPIS) : A geographic information system that allows the IACS to geo‑locate, 
display and spatially integrate its constituent data, as referred to in Article 70 of Regulation (EU) No 1306/2013 and 
Article 5 of Regulation (EU) No 640/20143. It contains diverse spatial data sets from multiple sources which together 
form a record of all agricultural areas (reference parcels) in the relevant Member State and the maximum eligible 
areas under different EU aid schemes in Pillars 1 and 2 of the CAP . LPISs comprise alphanumerical and graphic 
elements.
LPIS QA control zone : Randomly chosen zone used for the QA inspection, where up‑to‑date national ortho‑photo 
or very high resolution remote sensing data is available.
LPIS layer : The visual representation of a geographic dataset in any digital map environment. Conceptually, a layer 
is a stratum of the geographic reality in a particular area.
2 Regulation (EU) No 1306/2013 of the European Parliament and of the Council of 17 December 2013 on the financing, management and monitoring of the 
common agricultural policy and repealing Council Regulations (EEC) No 352/78, (EC) No 165/94, (EC) No 2799/98, (EC) No 814/2000, (EC) No 1290/2005 
and (EC) No 485/2008 (OJ L 347, 20.12.2013, p. 549).
3 Commission Delegated Regulation (EU) No 640/2014 of 11 March 2014 supplementing Regulation (EU) No 1306/2013 of the European Parliament and of 
the Council with regard to the integrated administration and control system and conditions for refusal or withdrawal of payments and administrative 
penalties applicable to direct payments, rural development support and cross compliance (OJ L 181, 20.6.2014, p. 48).
07 Glossary 
LPIS update : LPIS activities undertaken by Member States to record changes to land over time, e.g. by drawing the 
correct parcel boundaries, determining the degree of eligibility of agricultural land, delineating ineligible areas, 
defining pro‑rata categories for each reference parcel affected etc. It also includes LPIS activities undertaken by the 
Member States to ensure that their LPISs complies with the latest regulatory and technical requirements.
Maximum eligible area (MEA) : The number of potentially eligible hectares under a particular aid scheme or 
support measure. In the context of the LPISs, the MEA is capped by, among other factors, the reference area of the 
reference parcel.
On‑the‑spot check : Verification carried out by the paying agency’s inspectors of the legality and regularity of 
area‑aid transactions, involving a visit to the applicant’s premises or a review of recent satellite images of parcels 
(i.e. remote sensing). Such checks are to be conducted systematically and on an annual basis on a certain sample 
of agricultural holdings. For major schemes and their terms, e.g. for the basic payment scheme, the single area 
payment scheme or most rural development measures, 5 % of all relevant beneficiaries are subject to on‑the‑spot 
checks.
Ortho‑imagery : Ortho‑rectified (corrected for distortion) photographs, pictures and other images taken from 
airborne or satellite platforms.
Paying agency : A Member State body responsible for managing agricultural subsidies.
Permanent grassland and permanent pasture (together referred to as ‘permanent grassland’) : Land that is 
used to grow grasses or other herbaceous forage naturally (self‑seeded) or through cultivation (sown) and that has 
not been included in a holding’s crop rotation for at least five years. It may include other vegetation which can be 
grazed, such as shrubs and/or trees, provided that the grasses and other herbaceous forage remain predominant. 
At the discretion of the Member State in question, the definition may also include land which can be grazed and as 
part of established local practices but where grasses and other herbaceous forage are traditionally not predominant 
in grazing areas.
Quality assessment (QA) : An annual exercise in which Member States or regions test their LPIS data reliability on 
the basis of certain quality elements. The QA methodology is developed and refined by the JRC. The results of the 
exercise are monitored by DG Agriculture and Rural Development.
Quality element (QE) : One of six specific components used in QA to assess the quality of an LPIS and identify its 
weaknesses (Article 6 of Regulation (EU) No 640/2014).
Reference parcel : A geographically delimited area with a unique identification field, registered in the identification 
system for agricultural parcels referred to in Article 70 of Regulation (EU) No 1306/2013, with a default value of 
potentially eligible hectares under a particular aid scheme or support measure.
Statement of Assurance (SoA) : The result of an annual financial and compliance audit exercise in which we 
examine the reliability of the EU’s accounts and the regularity of the transactions underlying them. The findings and 
conclusions of the Statement of Assurance are published in our annual report.
08
 Executive summary
I
A Land Parcel Identification System (LPIS) is an IT system based on aerial or satellite photographs recording all 
agricultural parcels in the Member States. It is a key control mechanism under the Common Agricultural Policy 
(CAP) designed to verify eligibility for area‑based subsidies, which amounted to approximately 45.5 billion euro in 
2015. The Court’s Statement of Assurance (SoA) estimated the level of error for the European Agricultural Guarantee 
Fund (EAGF) at 2.9 % (2.2 % without cross‑compliance errors) in 2014. Close to half of the errors were area‑related. 
The system also increasingly plays a role in checking compliance with various environmental obligations. In the 28 
Member States, there are currently 44 national or regional LPISs in operation, containing over 135 million reference 
parcels.
II
We examined whether the LPISs were well managed by Member States and adequately monitored by the Commis ‑
sion. Audit visits were made to the Commission and five Member States (covering six LPISs). We also sent a survey to 
all the Member States.
III
We concluded that the LPIS is a useful tool for determining the eligibility of agricultural land but its management 
could be further improved. Over recent years our SoA results showed that action plans and financial corrections 
addressed LPIS shortcomings in the Member States affected. Some room for improvement remains, in particular:
‑ We identified some weaknesses in LPIS processes affecting the Member States’ ability to reliably check the 
eligibility of land. While LPIS ortho‑imagery was mostly up‑to‑date, photo‑interpretation was not always reliable 
or conclusive. In some of the LPISs additional information concerning ownership and lease rights was included 
in order to ensure that each parcel had been declared by the right farmer. In addition, Member States did not 
analyse the cost‑effectiveness of their LPISs in order to better design the related checks.
‑ We found that Member States had made progress in upgrading their LPISs to meet the 2014 ‑2020 CAP require ‑
ments. However, LPISs had not yet been completely adapted for greening. Some efforts by the Commission to 
simplify the CAP had had mixed results.
‑ Through improved LPIS‑related guidance, regular audits and follow‑up of Member States’ action plans and fi ‑
nancial corrections, the Commission’s performance of its monitoring role has improved. However, the reliability 
of the yearly quality assessment (QA) exercise on the effectiveness of the LPISs in the Member States was under ‑
mined by weaknesses in the applied methodology and insufficient checks and follow‑up by the Commission.
09 Executive summary 
IV
Following our audit observations, we recommend that:
(a) Based on a quantified cost‑benefit analysis and an assessment of risks, the Member States should strengthen 
their efforts to increase data reliability (by enhancing the update process, clarifying the use of the pro‑rata op ‑
tion and checking whether land is at the farmer’s disposal).
(b) With the support of the Commission, the Member States should develop and set up a framework for assessing 
the cost of running and updating their LPISs to measure the performance of their LPISs and the cost‑effective ‑
ness of system improvements.
(c) The Member States should ensure that, using their LPISs, they reliably identify and register, and then effectively 
monitor, ecological focus areas, permanent grassland and new categories of land.
(d) The Commission should re‑examine the current LPIS legal framework in order to simplify and streamline some 
of the rules for the next CAP period.
(e) The Commission should carry out a cost‑benefit analysis in order to determine whether the representative ‑
ness of QA samples could be improved so that a better coverage of the population of parcels in the LPIS can be 
achieved.
(f) The Commission should improve its monitoring of QA results by analysing any inconsistencies in QA reporting, 
following them up, providing feedback to the Member States and ensuring that remedial action plans are pre ‑
pared and executed when needed.
10
 Introduction
Background
01 
The Common Agricultural Policy (CAP) finances, via the European Agricultural 
Guarantee Fund (‘EAGF’), direct payments to farmers and measures to respond to 
market instabilities or environmental challenges (‘Pillar 1’). The CAP also co‑fi ‑
nances rural development programmes within the EU Member States (‘Pillar 2’) 
via the European Agricultural Fund for Rural Development (EAFRD). The reformed 
CAP for the 2014 ‑2020 period strives to achieve better targeted, more equitable 
and more environmentally friendly  – ‘greener’  – direct aid payments.
02 
To ensure that payments are regular, the CAP relies on the Integrated Admin ‑
istration and Control System (IACS), a set of comprehensive administrative and 
on‑the‑spot checks on subsidy applications, which is managed by the Member 
States. The Land Parcel Identification System (LPIS) is a key component of the 
IACS. It is an IT system based on ortho‑imagery (aerial or satellite photographs) 
which records all agricultural parcels in the Member States. It serves two main 
purposes: to clearly locate all eligible agricultural land contained within reference 
parcels and to calculate their maximum eligible area (MEA). The LPIS is used for 
cross‑checking during the administrative control procedures and as a basis for 
on‑the‑spot checks by the paying agency4.
03 
The LPISs were originally devised for checks relating to area‑based aid, which 
currently5 represents payments of up to 40 billion euro for CAP Pillar 16 and of 
around 5.5 billion euro for CAP Pillar 27. Some Member States have also used their 
LPISs to check whether farmers have respected some of the environmental rules 
under cross‑compliance or area‑related rural development schemes, such as 
agri‑environment and less‑favoured area support. During the 2014 ‑2020 CAP , part 
of the direct aid to farmers is to be paid for agricultural practices beneficial for 
the climate and the environment. Some of these new greening obligations (see 
paragraph 35 in Part II) are to be monitored using the LPIS.4 For the 2007 ‑2013 CAP period, 
the core LPIS legislation is 
Article 17 of Council 
Regulation (EC) No 73/2009 of 
19 January  2009 establishing 
common rules for direct 
support schemes for farmers 
under the common 
agricultural policy and 
establishing certain support 
schemes for farmers, 
amending Regulations (EC) No 
1290/2005, (EC) No 247/2006, 
(EC) No 378/2007 and 
repealing Regulation (EC) No 
1782/2003 (OJ L 30, 31.1.2009, 
p. 16) and Article 6 of 
Commission Regulation (EC) 
No 1122/2009 of 
30 November 2009 laying 
down detailed rules for the 
implementation of Council 
Regulation (EC) No 73/2009 as 
regards cross‑compliance, 
modulation and the 
integrated administration and 
control system, under the 
direct support schemes for 
farmers provided for that 
Regulation, as well as for the 
implementation of Council 
Regulation (EC) No 1234/2007 
as regards cross‑compliance 
under the support scheme 
provided for the wine sector; 
for the 2014 ‑2020 period, it is 
Article 70 of Regulation (EU) 
No 1306/2013 and Articles 5 
and 6 of Regulation (EU) 
No 640/2014.
5 According to the figures taken 
from the general EU budget 
for 2015.
6 Payment appropriations cover 
largely budget lines 
05 03 01 01, single payment 
scheme, 28 342 million euro; 
05 03 01 02, single area 
payment scheme, 
7 806 million euro and integral 
parts of 05 03 01 03 to 
05 03 03, Other direct aids, 
totalling 4 328 million euro 
overall (redistributive 
payment, specific programme 
for outermost regions, area aid 
for cotton and partially 
specific support (Article 68)).
7 The area‑related rural 
development schemes within 
budget line 05 04 Rural 
development account for 
roughly half of the payment 
appropriations of 
11 162 million euro.
11 Introduction 
LPIS specifications
04 
The LPIS operates on the basis of reference parcels. A reference parcel is 
a uniquely identified and geographically delimited agricultural area8. Farmers are 
expected to carefully examine each map and to identify and exclude from their 
applications all unfarmed land, and ineligible features on parcels, such as build ‑
ings, farmyards, scrub, roadways, forests, lakes, etc.
05 
The LPIS’s technical specifications vary from one Member State to another as vari ‑
ous types of reference parcel exist (see Table 1 ). A brief description of the main 
types is given below.8 See Articles 2(25) and 5(1) of 
Regulation (EU) No 640/2014 
as well as Article 4(1)(e) of 
Regulation (EU) No 1307/2013.Table 1Characteristics of the reference parcel types
Agricultural parcel Cadastral parcel Farmer's blockPhysical / Topographical 
block
Main features - Single crop group
- Single farmer- One or more farmers
- Based on ownership
- One or more crop groups- Single farmer
- One or more crop groups
- No natural boundaries- One or more farmers
- Area bordered by certain 
features (ditches, hedges, 
walls, etc.)
- One or more crop groups
Main data source Farmer’s application Cadastre, land register Farmer’s application Administrative classification
Source:  European Court of Auditors and European Commission (JRC).

12 Introduction 
06 
Belgium, Germany, and the United Kingdom have an LPIS for each region. All 
other EU Member States have one each covering the whole country. There are 
currently 44 LPISs in total, containing over 135 million reference parcels (see  
Figure 1 ).
07 
The LPISs are managed by the Member States, which are responsible for the 
quality of the data entered in their systems. The Commission plays a monitoring 
role. It provides guidance and support to the Member States, audits the effective ‑
ness of their LPISs, may apply financial corrections if there are failures in the LPIS 
checks and follows‑up on action plans. The Commission has also established the 
LPIS quality assessment (LPIS QA), which requires Member States to annually test 
the quality of their LPISs. Figure 1LPISs by type across the EU
Source: European Court of Auditors based on the 2014 and 2015 LPIS Quality Assessment Reports. 
 
  
Agricultural parcel
Cadastral parcel
Farmer’s block
Physical / Topographical block
13
 Audit scope, objectives and 
approach
08 
The purpose of this audit was to determine whether the Land Parcel Identifica ‑
tion System implemented under the Common Agricultural Policy was fit for 
purpose.
09 
We sought to answer the overall audit question:
Is the Land Parcel Identification System (LPIS) well managed?
10 
In order to answer this question, we checked whether the LPIS allowed Member 
States to reliably check the measurement and eligibility of land claimed by the 
farmers ( Part I ), and whether the systems were being adapted to meet the re ‑
quirements of the 2014 ‑2020 CAP , in particular those concerning greening obliga ‑
tions and the need to simplify the implementation of the policy ( Part II ). Finally, 
we examined whether the Commission was adequately fulfilling its monitoring 
role ( Part III ).
11 
We carried out the audit between July 2015 and April 2016. It included visits to 
the European Commission and to five Member States (Austria, Germany (Saarland 
and North Rhine‑Westphalia), Ireland, Poland and the United Kingdom (Scot ‑
land)). These Member States were selected on the basis of the amounts paid out 
there, their reference parcel system and on recent audit coverage by both us 
and the Commission. In each Member State, we carried out interviews, analysed 
procedures and data, and tested a sample of parcels to check the reliability of 
the data stored in the system. In total, over 400 reference parcels were checked 
on‑screen9 in the presence of the national authorities, of which more than 100 
were visited on‑the‑spot10. This sample was selected on a risk basis to identify 
possible areas for improvement of the LPISs.
12 
Furthermore, we sent a survey to the Member States covering all 44 different 
LPISs, in order to obtain key data and information on their set‑up and implemen ‑
tation. In addition, we conducted a documentary analysis of previous audit find ‑
ings by us and the Commission, as well as a review of previous studies. Further 
desk reviews were carried out to analyse additional information on the LPISs 
implemented by Member States or regions that were not visited during the audit. 
Finally, we held interviews with Commission officials and examined relevant 
documents in this context.9 This figure does not include all 
the reference parcels analysed 
on screen in North Rhine ‑
Westphalia. Here the audit 
team had unlimited access to 
a read ‑only version of the LPIS 
before, during and after the 
audit visit.
10 The scope of the on ‑the‑spot 
visits included mainly the 
assessment of both the correct 
determination of the eligible 
agricultural area and the 
coherence between the 
information registered in the 
related LPIS with the actual 
status of the reference parcel.
14
 Part I
Despite good achievements in the 
implementation of the Land Parcel Identification 
Systems, room for improvement remains
13 
In order to serve the intended purpose, LPIS data needs to be up‑to‑date, reli ‑
able and complete for administrative checks to be effective. Member States need 
to regularly update their ortho‑imagery and correctly assess it. In cases where 
photo‑interpretation is inconclusive, Member States should consider, based on 
an assessment of risks and costs of further controls, carrying out visits to the par ‑
cels concerned in order to correctly determine their maximum eligible area. All 
information relevant for assessing land eligibility should be included in the LPIS. 
With the support from the Commission, Member States also need to collect LPIS 
performance information, in order to weigh the cost of further improvements 
against the expected benefits.
Good achievements in the implementation of the LPISs
14 
We have regularly examined the implementation of LPISs in the Member States 
in the context of our annual Statement of Assurance. Provided the graphical 
information included in an LPIS is properly updated and analysed, the LPIS makes 
a significant contribution to preventing and detecting area‑related errors in 
aid applications. Thanks to improved guidance issued by the Commission (see 
paragraphs 57 to 59) and to action plans put in place by the Commission and the 
Member States (see paragraphs 60 to 61), the reliability of data in their LPISs has 
been constantly improving over recent years. Remedial actions have resulted 
in ineligible areas being excluded from the LPIS in several Member States and 
substantial financial corrections have been imposed by the Commission (see 
paragraphs 62 to 64).
15 
As part of the Statement of Assurance exercise, we annually estimate the level of 
error for the EAGF. In 2014, based on the 183 transactions audited, we estimated 
it at 2.9 %11. The figure was close to but above the materiality threshold of 2 %. 
Area‑related errors accounted for 44 % of the estimated 2014 EAGF error rate. 
Half of these errors were less than 2% and thus had only a limited impact on the 
overall estimated level of error.
Ortho‑imagery was mostly up‑to‑date
16 
Member States must regularly update their LPISs in order to be able to check that 
farmers are only paid for eligible agricultural area. Given the potential for natural 
or anthropogenic changes to parcels, Member States mainly focus their efforts on 
frequently supplying new ortho‑imagery and promptly entering it into their LPIS. 
This is necessary in order to ensure that the system reliably and correctly reflects 
the site‑specific conditions.11 The EAGF estimated level of 
error without cross‑
compliance was 2.2% in 2014.
15
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
17 
Outdated ortho‑imagery carries with it the risk of LPIS data no longer being 
accurate. The Commission has recommended that, in principle, the LPIS dataset 
should be updated over a 3 ‑5 year period12, so that the system contains a reflec ‑
tion of the situation on the ground. For a significant portion of parcels in Scot ‑
land, we found that the LPIS photos were not always renewed every five years 
(see Box  1).12 DG Agriculture and Rural 
Development, 2014 Annual 
Activity Report, Final report, 
Annex 10, Part 3.2, ABB 03: ‘It is 
therefore necessary to keep 
the LPIS up to date, and in 
order to do so, Member States 
should consider a constant 
refresh of the ortho ‑imagery 
over a 3 ‑5 year period 
depending on the evolution of 
the terrain (via human 
intervention or absence 
thereof).’
Example of outdated ortho‑imagery in the LPIS
In Scotland , we came across photos that had been taken in 2008 and 2009, and were therefore over seven 
years old. The authorities estimated that over 35 000 of the parcels in the LPIS (6.9 % of the total) had been 
photographed before 2010.Box 1
18 
During the audit, we identified good practices as regards the regular acquisi ‑
tion of LPIS ortho‑imagery e.g. in Austria, Germany (North Rhine‑Westphalia and 
Saarland) and Poland.
19 
Certain Member States have made specific efforts to introduce the new set of 
ortho‑imagery on a timely basis. In 2015, North Rhine‑Westphalia even entered 
into its LPIS ortho‑photos that have been taken in spring of that same year (as 
‘provisional digital aerial photographs’). Such prompt action helps to keep the 
system up‑to‑date and reduces the number of time‑consuming and laborious 
recoveries in the event of changes in the eligibility of land. In addition, historical 
ortho‑photos are stored in the system and can be displayed to reveal the earlier 
state of an LPIS reference parcel.
16
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
20 
We found also cases of longer delays in new ortho‑imagery being entered into 
the LPIS. In Austria, this exercise took more than a year. In Scotland there were 
also significant delays13 in updating the LPIS, due mainly to the shortage of staff 
for photo‑interpretation but also to delays in receiving new ortho‑imagery from 
the contractor.
Photo‑interpretation was not always reliable or 
conclusive
21 
Apart from regularly renewing the ortho‑imagery, systematic and accurate 
interpretation of the new ortho‑photos is critical in order to ensure that eligible 
agricultural area is correctly recorded and ineligible area correctly excluded in 
the LPIS. Only if national authorities are able to correctly interpret the photos 
they receive will they be able to perform reliable administrative checks on farm ‑
ers’ applications. The Commission recommends that once new ortho‑imagery is 
received, national authorities should conduct photo‑interpretation in a systemat ‑
ic way. One paying agency we visited (Saarland’s), had no such systematic picture 
interpretation process in place.
21 
Our audit confirmed14 that photo‑interpretation undertaken during LPIS updates 
was not always reliable, resulting in incorrect maximum eligible areas (MEAs) 
being recorded in the respective LPISs. Specifically, areas or clearly ineligible 
features were incorrectly delineated (see Box  2).13 For the 2014 flights, out of 
160 000 parcels covered, only 
90 000 had been processed by 
October 2015.
14 In this context see also our 
2014 Annual Report and, in 
particular, recommendation 1 
of chapter 7: ‘the Member 
States make further efforts to 
include reliable and up ‑to date 
information in their LPIS 
databases on the size and 
eligibility of agricultural land, 
notably of permanent pasture, 
and systematically analyse 
and use all the information 
available in the context of 
administrative checks, 
including up ‑to‑date 
orthoimages, in order to avoid 
payments for ineligible land’ 
(OJ C 373, 10.11.2015).
17
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Examples of incorrect assessment of MEA which could have been identified by 
photo‑interpretation
Ineligible area incorrectly assessed
In Saarland , we identified parcels that were recorded as being fully eligible, when in fact it was obvious from 
the newly acquired photos that they were mostly ineligible (overgrown).Box 2
Image in the Saarland LPIS
© Paying Agency Saarland
Situation found on‑the‑spot
Source : European Court of Auditors© Scottish Paying AgencyIn Scotland , we identified ineligible areas incorrectly registered in the LPIS. The LPIS contained a reference 
parcel partially covered by steep slope and rocky land without green cover as being completely eligible. The 
red arrows indicate some of the problematic areas.
18
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
23 
Sometimes, photo‑interpretation alone is not sufficient to accurately assess the 
eligibility of land on ortho‑photos. In the case of arable land or plain grassland, 
photo‑interpretation can, in general, reliably identify the eligible area to be 
registered in the LPIS. This is, however, not always the case for specific types of 
grassland, such as grazed woodland or alpine pasture (see Box  3).Ineligible features not properly excluded
In Austria , a lake was incorrectly delineated. The parcel also included a house in the maximum eligible area.
In Ireland , a parcel was assigned a maximum eligible area of 1.4 ha in the LPIS after the farmer had submit ‑
ted a change in the area, despite the fact that the parcel included the farmyard and a shed and was thus fully 
ineligible.
We found other examples in North Rhine‑Westphalia  of weaknesses in determining the correct maximum 
eligible area.Box 2
© Austrian Paying Agency (AMA)
19
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Photo‑interpretation alone is not always conclusive
In Scotland , we found parcels that had been claimed for as grazed woodland (see the LPIS image on the left), 
but were in fact ineligible for payment as either not grazed or not grazable at all because there was no grass 
underneath (see the LPIS image on the right). This could only be confirmed during an on‑the‑spot visit. The 
parcels were incorrectly included in the maximum eligible area and had been granted payment in the past.Box 3
Image in the Scottish LPIS
© Scottish Paying Agency
Situation found on‑the‑spot
Source:  European Court of Auditors
Image in the Scottish LPIS:
© Scottish Paying Agency
Situation found on‑the‑spot
Source:  European Court of Auditors
20
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
24 
Where doubts exist as to whether parcels – especially grassland – are actually 
being used for agricultural purposes, some Member State authorities undertake 
field visits as part of the update process to support their on‑screen photo‑inter ‑
pretation. We noted efforts in this regard in Austria (alpine pastures) and Scot ‑
land, but also a sizeable backlog of such visits in the latter region (over 76 000 
land‑review visits), which had been scheduled in order to ensure that the infor ‑
mation in the LPIS was up to date but had not yet been carried out, mainly due to 
a lack of resources.
25 
While ad‑hoc field visits are the only method for ensuring accuracy when pho ‑
to‑interpretation is not conclusive, they come at a cost. Their number and scope 
should therefore be carefully planned by weighing the cost of additional accu ‑
racy against the expected benefits in terms of regularity of payments.In certain cases, the eligibility of the parcel depends on whether or not there is grass underneath trees or 
other vegetation, e.g. fern, gorse or bracken. In extreme cases, as confirmed in Ireland , this could drastically 
change an eligibility assessment, but cannot be captured by photo‑interpretation.
Bracken with grass underneath  
(eligible or partially eligible in Ireland)
Source:  European Court of Auditors
Bracken with no grass underneath  
(not eligible in Ireland)
Source:  European Court of Auditors
We found other examples of weaknesses concerning grassland parcels in Austria  and North 
Rhine‑Westphalia .Box 3
21
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Pro‑rata was not always applied reliably
26 
Member States have the option of using a pro‑rata system in their LPISs for per ‑
manent grassland reference parcels containing both eligible agricultural land and 
ineligible natural features such as scrub, trees, rocks, bushes or rushes. In order to 
determine the eligible area within reference parcels, Member States establish dif ‑
ferent ranges of eligibility percentages, which impact the payment accordingly15. 
This is to serve the purpose of simplifying the determination of eligible area on 
parcels where the exact eligibility rate is not self‑evident. Man‑made construc ‑
tions such as buildings, permanent streets or concrete walls do not fall into this 
category but have to be exempted and delineated in the LPIS before applying 
pro‑rata.
27 
Under the pro‑rata system, photo‑interpretation or automatic assessments, 
without any reflection or, where necessary, confirmation on the spot, is generally 
not sufficient to reliably determine the correct eligible areas. During our audit, 
we visited a number of alpine parcels in Austria16 and commonages in Ireland17 
for which a pro‑rata assessment had been made. We observed on‑the‑spot that 
national inspectors and/or photo‑interpreters found it difficult to consistently de ‑
lineate parcels, apply the range of eligibility coefficients and establish individual 
eligibility percentages (see Box  4). National authorities had not built appropriate 
risk management strategies such as comprehensive and illustrative pro‑rata cata ‑
logues with clear description and assessment criteria for each range, field visits in 
all doubtful cases or complementary technical tools to resolve these difficulties 
in a satisfactory manner.
28 
The Commission recommends that Member States should take great care when 
assessing grasslands with an eligibility coefficient of below 50 %, as it bears 
a high risk of error18. In Austria, a system was implemented for calculating the 
area of mountain pastures, which are strewn with trees, stones and other debris. 
Both the Austrian and the Irish pro‑rata systems allowed for low eligibility coef ‑
ficients (see Box 5  for an example related to Austria).15 Article 10 of Commission 
Delegated Regulation (EU) No 
640/2014.
16 Five alpine pastures in the 
regions of Niederösterreich, 
Steiermark, Salzburg and 
Oberösterreich.
17 Four commonage parcels in 
Ireland, which are typically 
larger pieces of pastureland 
owned by more than one 
person. Each shareholder 
owns a notional share of the 
total area.
18 JRC, Technical guidance on 
the pro rata system for 
permanent grassland, 
DS‑CDP‑ 2015 ‑06 final.
22
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Example of incorrect pro‑rata assessments, revealing the limitations of LPIS 
imagery
In Ireland , a grassland parcel covered partially with bushes, trees, fern and heather recorded in the LPIS as 
being 90 % eligible, was assessed during the audit visit as being only 70 % eligible, meaning that part of the 
payment might have been overstated.
Example of parcels with low eligibility coefficients
A woodland reference parcel shown below, with little grass cover underneath the trees, was recorded in the 
Austrian  LPIS as being 21 % eligible. On‑the‑spot, we found that the rate was overstated.Box 4 Box 5Image in the Irish LPIS
Image in the Austrian LPIS
© Irish Paying Agency (DAFM) © Austrian Paying Agency (AMA)Situation found on‑the‑spot
Situation found on‑the‑spot
Source:  European Court of Auditors Source:  European Court of Auditors

23
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Semi‑automated detection tools were being tested, 
but were not yet operational
29 
One way to mitigate the risk of incorrectly registering eligible area in an LPIS and 
to achieve more objective results is to develop and apply automatic change‑de ‑
tection tools. Based on ortho‑imagery, software may help to perform photo‑in ‑
terpretation by identifying shapes, objects, textures or relations to adjacent 
segments. Member States such as Austria and Ireland were giving consideration 
to a range of such tools for LPIS data interpretation. While testing is not yet 
conclusive (see Box  6), we acknowledge their interest in making continuous im ‑
provements to data reliability and using innovative techniques, in order to both 
improve reliability and reduce administrative costs.
The results achieved by semi‑automatic detection tools in Austria
In Austria , a study was recently conducted to test the reliability of a semi‑automatic detection tool developed 
by the University of Natural Resources and Life Sciences in Vienna. Comparing the results for eligible areas 
registered in the Austrian LPIS (left image) with those determined by means of a semi‑automatic detection 
tool (right image) reveals significant differences.Box 6
Source:  ©Atzberger, C., ‘The current capabilities of (semi-)automatic determination of pasture grazing areas using re -
mote sensing’, Vienna 2014.

24
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Information on whether the land is actually at the 
farmer’s disposal was included in some LPISs
30 
Farmers need to have the claimed area at their disposal (e.g. through ownership 
or lease rights) in order to be entitled to any agricultural payment. If farmers are 
not asked to provide evidence of legal rights on the land they claim, then there 
is the risk that they are paid for land that it is not at their disposal, such as public 
land or private land belonging to other entities. Though not required by the EU 
legislation, we consider it good practice to complement the LPIS, whenever feasi ‑
ble and cost‑effective, with information on whether the parcels are at the farm ‑
er’s disposal, which would enable Member States to cross‑check such information 
against aid applications, as we found in Scotland (see Box  7).
Good practice with regard to verification of evidence of the right to use the land
In Scotland , any declared change in ownership or of the right to use parcels must be supported by appropri ‑
ate background documents signed by both parties to the transfer. Similarly, all newly declared parcels must 
be supported by a document proving the right to use the land. The Scottish LPIS contains information about 
land ownership and/or tenancy agreements.Box 7
31 
The remaining four audited Member States do only occasionally require farm ‑
ers to provide evidence of ownership, lease or any other rights on the land they 
claim, and therefore cannot always be sure whether the reference parcels regis ‑
tered in their LPISs are fully and legally at the farmer’s disposal. We found cases in 
Austria and North Rhine‑Westphalia where parts of parcels adjoining woodland 
or at roadsides were not at the disposal of the farmer but had nonetheless been 
declared and paid. The relevant information from the land register, already incor ‑
porated into the LPIS, had not been used as an additional source of information.
25
Part I - Despite good achievements in the implementation  
of the Land Parcel Identification Systems, room for 
improvement remains
Insufficient information for fully assessing the 
cost‑effectiveness of implementing the LPIS
32 
The LPIS’s main functions are to locate, identify and quantify agricultural land. As 
described in paragraphs 16 to 29, Member States put significant financial resourc ‑
es into establishing, running and updating their LPISs. We therefore attempted to 
gather LPIS cost information from Member States and the Commission. Member 
States were not able to provide reliable and comparable cost information. They 
had difficulties in quantifying the overall investment cost of their LPISs, their 
annual running costs and the cost of specific features, such as the LPIS update 
process or the different LPIS layers or QA. The Member States are therefore not in 
a position to assess the cost‑effectiveness of system improvements.
33 
The Commission has information on setting up LPISs in new Member States and 
information on imagery costs. However, the Commission had not requested infor ‑
mation on running costs from the Member States, nor provided guidance on how 
to produce it in a reliable and comparable way. The Commission is therefore not 
able to assess adequately the costs associated with new system requirements or 
policy developments.
26
 Part II  
The Land Parcel Identification System was being 
upgraded to meet the requirements of the  
CAP reform
34 
An upgrade of the Member State LPISs is needed in order to meet the new re ‑
quirements of the 2014 ‑2020 CAP . The changes relate mainly to the new manda ‑
tory greening requirements which tie an additional 30 % on top of the basic pay ‑
ment to certain practices which are potentially beneficial for the climate and the 
environment throughout the EU. We analysed the extent to which the LPIS can 
serve to monitor these greening requirements. In that context, we also examined 
the voluntary inclusion in their LPISs by some Member States of certain landscape 
features protected under cross‑compliance and rural development. Furthermore, 
because one of the Commission’s key priorities is simplifying the CAP in order to 
achieve better results through less complicated rules, we also analysed the Com ‑
mission’s efforts in this respect.
The adaptation of LPISs by Member States for 
greening was progressing but was not yet complete
35 
The new 2014 ‑2020 Common Agricultural Policy (CAP) introduced ‘green direct 
payments’. In order to receive these payments, farmers are required to maintain 
permanent grassland, apply crop diversification and dedicate a share of arable 
land to ecological focus areas (EFA)19 (see Figure  2).
36 
While the LPIS can be an effective tool for monitoring permanent grassland and 
some ecological focus areas (see paragraphs 37 to 41), it is less so for require ‑
ments of a more temporary nature such as crop diversification (see Figure 2 ). 
Thus, LPIS is not an appropriate tool to allow the paying agency to administra ‑
tively check whether crop diversification has actually taken place.19 Regulation (EU) No 1307/2013.
27
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reformFigure 2Greening: a basic overview
Source:  European Commission.
30 % of the direct payment envelope for applying three basic practices: 
Equivalence: Member States may decide that, instead of applying these three practices, farmers can undertake practices 
considered equivalent (e.g. crop rotation instead of crop diversi/f_ication). Maintaining an ‘ecological focus area’ of at least 5 % of the arable area of the holding 
 √   only applies to farms with more than 15 hectares of arable land 
 √   ratio may rise to 7 % after a Commission report in 2017 and a legislative proposal 
 √   EFAs may include: /f_ield margins, buﬀer strips, fallow land, landscape features, aﬀorested areas, terraces, areas with 
       catch crops, green cover and nitrogen-/f_ixing crops, short rotation coppices, agri-forestry, strips of land along forest 
            edges Crop diversiﬁcation 
 √   at least 2 crops when the arable land of a holding exceeds 10 hectares 
 √   at least 3 crops when the arable land of a holding exceeds 30 hectares 
 √  the main crop may cover at most 75 % of arable land, and the two main crops a maximum of 95 % of the arable area Maintaining permanent grassland  
√   ban on ploughing in designated areas 
 √   national/regional ratio with a 5 % /f_lexibility margin
28
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
Weaknesses in Member States’ determination of 
permanent grassland
37 
Permanent grassland has been widely recognised for its positive environmental 
effects and should be protected. It is land that is used to grow grass or other her ‑
baceous forage either naturally (self‑seeded) or through cultivation (sown) and 
that has not been included in the holding’s crop rotation for at least five years20. 
Restrictions are placed, by law, on converting permanent grassland back into ar ‑
able land. In order to avoid a substantial decline, Member States are required to 
ensure that the ratio of permanent grassland areas to the total agricultural area 
declared by farmers does not decrease by more than 5 %21.
38 
We identified an example of good practice in Saarland where an LPIS sub‑layer 
made it possible to trace and monitor the transition of individual parcel compo ‑
nents to permanent grassland at the smallest possible level, for example in cases 
of parcel divisions or mergers. However, in the other five Member States / regions 
visited, there were risks that changes to existing permanent grassland or land 
which is supposed to become permanent grassland might go undetected due to 
inappropriate monitoring and incomplete source data in the LPIS (see Box  8).
The EFA layer was currently under development by 
Member States
39 
According to the new legislation, Member States have to register all permanent 
ecological focus areas in a layer in their LPISs by 2018, in order to check whether 
farmers have complied with their obligation to generally maintain at least 5 % of 
their land as ecological focus areas22.
40 
The graphic material supplied to beneficiaries from the 2016 claim year onwards 
must indicate the type, size and location of the EFAs determined during the 
previous year, including those that are non‑permanent23. To comply with this 
provision, Member States will need to have a basic EFA layer in place in their 
LPISs before 2018. A Commission guidance paper requests that, from the first 
year (2015), the EFA layer should contain all potential EFAs chosen by the Member 
State which are expected to remain stable for at least three years24. The Commis ‑
sion’s interpretation is intended to ensure that the EFA layer is gradually built up 
in order to be fully operational by 2018.20 Article 4(1)(h) of Regulation 
(EU) No 1307/2013.
21 Article 45(2) of Regulation (EU) 
No 1307/2013.
22 For the purpose of calculating 
this percentage, landscape 
features for example are not 
counted with their area as 
such, but are weighted and 
converted into hectares.
23 Article 17(4) of Commission 
Implementing Regulation (EU) 
No 809/2014 of 17 July 2014 
laying down rules for the 
application of Regulation (EU) 
No 1306/2013 of the European 
Parliament and of the Council 
with regard to the integrated 
administration and control 
system, rural development 
measures and cross 
compliance (OJ L 227, 
31.7.2014, p. 69).
24 DG Agriculture and Rural 
Development; EFA layer 
guidance document 
(DSCG/2014/31 final rev1).
29
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
41 
In our survey, a majority of Member States / regions (26 out of 44) informed us 
that they had already fully implemented the EFA layer in their LPISs, and the other 
18 were on course to do so by 2018, as required by the Regulation. The digitisa ‑
tion of all permanent ecological focus areas on or adjacent to arable land is being 
phased in by the Member States visited. However, Scotland has not yet digitised 
any EFAs in its LPIS and North Rhine‑Westphalia has not correctly determined 
the EFA categories and their sizes in all cases, leading to miscalculations, since 
the coefficients are different for certain elements such as hedges or field copses, 
for example25. In Ireland, when introducing the EFA layer with the permanent 
landscape features into the LPIS, the authorities decided to use a different set 
of information from that used by the National Mapping Agency for locating EFA 
elements such as hedges and drains. As this layer does not technically match the 
current Irish LPIS layer, boundaries and polygons of the EFA elements in the LPIS 
are shifted, making it challenging to locate them exactly.25 See Annex X of Regulation 
(EU) No 1307/2013; e.g. 1 m of 
hedge (conversion factor 5 
and weighting factor 2) counts 
for 10 m2 ecological focus area, 
while 1 m2 of a field copse 
(weighting factor 1.5) counts 
for only 1.5 m2.Weaknesses in the monitoring of permanent grassland
The type of agricultural land needs to be monitored year by year using the LPIS, in order to decide whether 
arable land has become permanent grassland, which is the case if, for five years or more, it has generally been 
used to grow grass and other herbaceous forage, despite having been ploughed up and seeded with another 
variety of herbaceous forage.
Traceability of the 5 ‑year conversion period not ensured
In Austria , if reference parcels are transferred between farmers or change in size, their links to the previous 
years are lost. As a consequence, the status of the land in the LPIS can no longer be reliably identified and po ‑
tential permanent grassland remains undetected. The same applies in Poland  and Scotland , as these LPISs do 
not include information on the age of non‑permanent grassland (e.g. second or third year of grass cover). The 
authorities are therefore unable to keep track of grassland parcels to ensure that they are re‑registered in the 
LPIS as permanent grassland after the end of the five‑year cycle. A similar situation exists in Ireland .
Exact location of permanent grassland not referenced in the LPIS
In North Rhine‑Westphalia , it is not generally possible to distinguish between permanent grassland and 
arable land within a reference parcel. As farmers’ drawings of agriculturally‑used area, which were part of 
the application for support, were not transferred into the LPIS, the exact shape of permanent grassland and 
potential permanent grassland could not be tracked.Box 8
30
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
Weaknesses in the registration of landscape elements 
protected under cross‑compliance or the 
agri‑environmental scheme
42 
The protection of EFAs is a continuation of other policies or instruments to pro ‑
mote a more environmentally‑friendly agriculture such as cross‑compliance or 
agri‑environment‑climate measures within the framework of rural development. 
As part of these rules, Member States have defined standards for the protection 
of environmentally sensitive areas and certain types of landscape elements (such 
as bushes, trees, buffer strips or field copses).
43 
The current EU legal framework does not oblige Member States to map in the 
LPIS landscape elements protected under cross‑compliance. Nonetheless, in the 
ECA survey, 28 Member States / regions declared they had done so pursuant to 
national law. 16 Member States / regions reported that these elements were not 
fully registered in the LPIS. Three out of the five Member States visited registered 
in their LPISs landscape elements protected under cross‑compliance. The correct 
identification and registration of such elements in the LPISs is useful in order to 
keep track of potential changes or instances of non‑compliance including the 
forbidden removal or destruction of such elements over time and would provide 
effective support for administrative cross‑checks. The same applies to Member 
States such as Austria, which pay agri‑environment‑climate aid for certain types 
of landscape elements. We found weaknesses as regards the correct identifica ‑
tion and registration of such elements in the Austrian and German LPISs (see 
Box  9). The difficulties in implementing reliable landscape element layers in LPISs 
illustrate the challenges ahead in introducing a comprehensive and effective EFA 
layer.
31
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
Examples of incorrect identification and registration of landscape elements
In North Rhine‑Westphalia , landscape elements protected under cross‑compliance were not always cor ‑
rectly delineated. Certain parts of the excluded landscape elements shown below (outlined in orange), such 
as field copses or lines of trees, were in fact eligible, while some other landscape elements of the same type 
remained unregistered.Box 9
© North Rhine -Westphalian Chamber of Agriculture
In Austria , the paying agency routinely recorded strips of forested area as landscape elements (field copse – 
blue triangle) even though they are a component of neighbouring forests. This generally means that the farms 
which cultivate the adjacent agricultural area do not have rights over them, and that they therefore do not 
fulfil the requirements for aid under the agri‑environmental scheme.
© Austrian Paying Agency (AMA)
32
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
Simplification is ongoing but remains a challenge
44 
Simplification is a primary goal of the Commission26. It considers simplifying the 
CAP to be essential in order to make the agricultural economy more competi ‑
tive, preserve and create jobs and contribute to the sound development of rural 
areas27. In principle, simplification should also apply to the LPIS.
45 
A new set of LPIS‑related rules in specific Regulations28 was adopted, together 
with the greening requirements. They include additional requirements (e.g. the 
obligatory geospatial aid application, more LPIS layers (see the list of obligatory 
LPIS layers in the Annex  I)) and options (i.e. the stability threshold, the 100 ‑tree 
rule) for the Member States. Finally, the integration of new categories of eligi ‑
ble land presents further challenges for LPISs due to varying established local 
practices.
The geospatial aid application ‑  a useful tool
46 
For the purpose of identifying all agricultural parcels used by a single beneficiary 
and for processing the corresponding spatial and alphanumerical data, Member 
State authorities must provide all beneficiaries with a pre‑established geospatial 
application form and the corresponding graphic material by 201829. In our LPIS 
survey, 33 Member States / regions told us that such a system was already in 
place to indicate how all aid applications intersected spatially with the informa ‑
tion in the LPIS. In the remaining 11 Member States / regions30, such a system was 
not (yet) in place.
47 
In principle, farmers should in the near future start submitting their aid applica ‑
tions using geospatial methods, i.e. the position and size of their parcels must 
be derived from imagery captured in the LPIS. However, as from 2018 when the 
system will have to be fully in place, only where beneficiaries are not in a position 
to do this, the national or regional authorities should provide them either with 
technical assistance or provide the aid‑application on paper and the authorities 
should ensure that all declared areas are digitised.26 See http://www.consilium.
europa.eu/en/policies/
cap‑simplification .
27 See http://ec.europa.eu/
agriculture/simplification/
index en.htm .
28 Regulation (EU) No 1306/2013 
and Commission Delegated 
Regulation (EU) No 640/2014 
and Commission 
Implementing Regulation (EU) 
No 809/2014.
29 Article 17 of Regulation (EU) 
No 809/2014.
30 This figure includes eight 
German regions.
33
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
48 
As our audit findings show, where it has been introduced, the geospatial aid ap ‑
plication has significantly improved the quality of information in the LPISs (e.g. in 
Austria and Saarland). During administrative checks, overlaps in the geometry of 
reference/agricultural parcels or inconsistencies in parcel boundaries generating 
error codes are immediately identified. In this context, Poland, too, has already 
developed an electronic geospatial aid application system to allow farmers to 
apply online. However, in the 2015 claim year, fewer than 1 % of applications 
were lodged electronically as Polish farmers had a preference for traditional 
paper‑based applications.
The visited Member States decided not to apply the 
stability threshold
49 
A new component of the 2014 ‑2020 CAP framework is the option for Mem ‑
ber States to not update their LPISs if the difference between the new MEA of 
a reference parcel and the MEA as previously assessed is below 2 % (the ‘stability 
threshold’)31. This new rule aims to simplify the administrative handling of the 
LPIS. However, the Commission provided guidance32 to the Member States indi ‑
cating that, although no update is legally required when the difference is below 
2 %, it is nonetheless recommended to do so (i.e. to exclude the ineligible parts 
for the MEA) for any manifest changes33 in the eligible area, regardless of whether 
the change is below the 2 % threshold. None of the Member States visited during 
the audit chose to use the 2 % stability threshold.
The optional 100 ‑tree rule ‑ a complicated exercise
50 
The new CAP framework contains a provision that areas with scattered trees on 
agricultural land are now considered eligible if there are no more than 100 trees 
per hectare and agricultural activities can be carried out in a similar way as on 
parcels without trees in the same area34. Trees which are considered ‘grazable’ 
(can be grazed) should not be counted for the 100 ‑tree threshold. ‘Grazable’ trees 
are those which, according to the Commission’s interpretation, are actually acces ‑
sible in their entirety to farm animals for grazing. Our analysis confirmed that it 
is difficult to identify such trees by photo‑interpretation which further translates 
into uncertainty in assessing land’s (partial) eligibility for agricultural aid, and 
entails complication and administrative burden for Member States.31 Article 5(3) of Regulation (EU) 
No 640/2014.
32 DSCG/2014/33 – final rev 3, 
section 3.2.
33 the appearance of an 
ineligible feature (ex. a newly 
built house).
34 Article 9(3) of Regulation (EU) 
No 640/2014: An agricultural 
parcel that contains scattered 
trees shall be considered as 
eligible area provided that 
agricultural activities can be 
carried out in a similar way as 
on parcels without trees in the 
same area; and the number of 
trees per hectare does not 
exceed a maximum density. 
This density shall be defined 
by Member States and notified 
on the basis of traditional 
cropping practices, natural 
conditions and environmental 
reasons.
34
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
New specifications of eligible land presented 
challenges for the LPIS
51 
New specifications and clarifications in relation to eligible land were introduced 
in the 2014 ‑2020 CAP provisions. As a general rule, only agricultural land record ‑
ed in LPISs that is predominantly used for agricultural activities qualifies for the 
Pillar 1 payments. Eligibility is determined by the status of land (arable land, per ‑
manent grassland, and permanent crops) and by its use. Acceptable activities are 
agricultural production (e.g. growing of crops) or maintenance in a state which 
makes the area suitable for grazing or cultivation. The latter requires either that 
farmers carry out a regular (e.g. annual) minimum maintenance activity on this 
land, or that this land has certain characteristics making it suitable for grazing or 
cultivation. This is in principle relevant for all types of land.
52 
Where Member States have defined a ‘minimum maintenance activity’ on land 
not used for production, its performance is unlikely to be verifiable in the LPIS. 
Only areas completely overgrown for more than a limited period, thus indicat ‑
ing no activity, might be identifiable in the LPIS, by comparing actual photos 
with older information stored in the system. On the other hand, it is the duty of 
Member States to verify the correct status of the reference parcels affected, and, 
once verified, e.g. by means of on‑the‑spot checks, to register it correctly in their 
LPISs (see Box  10).Box 10Good practice for registering a minimum maintenance activity in the LPIS
In Croatia , a specific code is used for reference parcels on which a minimum maintenance activity is declared, 
designating them ‘temporarily ineligible’ if on‑the‑spot checks show that the activity has not in fact been car ‑
ried out. A different code is used for areas that are permanently ineligible. This is a good solution for register ‑
ing non‑compliance with the minimum maintenance activity requirement in the LPIS.
35
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
53 
A new category of eligible permanent grassland concerns ‘areas which can be 
grazed and which form part of established local practices and where grasses and 
other herbaceous forage are traditionally not predominant’. Member States must 
identify and define such areas and register them in their LPISs. Typically, these 
will be areas of limited agricultural potential consisting of heather (e.g. in Ger ‑
many) or common grazing land (in Portugal), and visually they may appear to be 
abandoned or poorly maintained. Picture interpretation in the LPIS, as we found 
in Ireland and North Rhine‑Westphalia, is therefore often not sufficient to accu ‑
rately identify this type of land as eligible. The same applies for minimum main ‑
tenance activity (see paragraph 52). A more risk‑based approach by the national 
authorities is required, like targeted on‑the‑spot visits (see also paragraphs 23 to 
25) or the use of semi‑automatic tools (see paragraph 29).
Current efforts by the Commission to simplify the LPIS 
not yet complete
54 
Finally, we analysed the Commission’s efforts, in relation to the LPIS, to simplify 
the new 2014 ‑2020 CAP framework since its introduction. Six major changes po ‑
tentially affecting the LPIS were introduced in May 2015 (see Figure  3):Figure 3Changes introduced by the new CAP with impact on LPIS
Source:  European Commission.
(a) option of  a limited buﬀer area between the parcel boundary and an adjacent EFA, in duly justi/f_ied cases
(b) hedges or wooded strips can have gaps of up to 4 metres
(c) a missing EFA may be compensated for by another EFA, even if the latter  has not been declared
(d) option of mapping only declared EFAs in the LPIS
(e) changes to the identi/f_ication of EFAs in the EFA layer
(f) changes in the approach of identi/f_ication of speci/f_ic types of permanent grassland in the LPIS 
36
Part II - The Land Parcel Identification System was being 
upgraded to meet the requirements of the CAP reform
55 
According to our analysis, these changes benefit either the beneficiary (points (a) 
to (c)) or the paying agency (points (d) to (f)), but not necessarily both. The com ‑
plexity of the rules and the procedures required to deal with changes (a) to (c) 
in particular has further increased the administrative burden for Member States, 
as it is difficult to determine the correctness of the buffer and the increased al ‑
lowed gaps of up to four metres in the LPIS. Furthermore, the fact that missing 
or incorrectly determined EFAs can be compensated for by other EFAs makes the 
on‑the‑spot checks more time‑consuming. The final verdict on farmer’s compli ‑
ance cannot simply be reached by analysing the information on EFAs included in 
the initial claim against the information in the LPIS: in cases of non‑compliance, 
further action by the Member State authorities might be required.
37
 Part III  
The Commission’s LPIS monitoring improved but 
did not focus enough on LPIS performance
56 
The Commission has an important monitoring role in relation to the LPIS, helping 
to ensure that the LPISs managed by the Member States are effective and effi ‑
cient. Firstly, it should provide adequate support and guidance to Member States 
to promote consistent interpretation of EU rules and an effective monitoring of 
CAP payments. The Commission also regularly audits the different LPISs in the 
Member States and regions to gain assurance that they are functioning properly 
and protect the EU budget by applying financial corrections if major weaknesses 
are identified. The action plans drawn up to remedy these weaknesses in LPISs 
should also be closely followed‑up by the Commission. Through the LPIS QA, 
the Commission should have a reliable overview of the effectiveness of the LPISs 
across the EU and be able to assess progress made by the Member States on 
any weaknesses revealed. Finally, knowledge of the cost‑effectiveness of checks 
associated with the LPIS could help better target them where they are more 
efficient and better assess the implementation and control costs of new policy 
developments.
The Commission’s LPIS‑related guidance improved 
compared to the previous CAP period
57 
In the previous 2007 ‑2013 CAP period, the Commission did not establish any spe ‑
cific guidelines for the LPIS. This situation changed significantly for the 2014 ‑2020 
CAP , and a number of LPIS‑related guidelines were issued in 2014 and 201535.
58 
The Commission set up a unit36 devoted exclusively to the implementation of 
direct payments, with the aim of strengthening its guidance and support for 
Member States in the lead‑up to implementation of the CAP reform in 2015. 
Especially since 2014, the Commission has intensified its provision of information 
to and communication with Member States, for example by holding a series of 
bilateral meetings, publishing material or organising regular workshops in con ‑
nection with the LPIS.
59 
While the Commission’s LPIS‑related guidance improved compared to the 
previous CAP period, it essentially focuses on aspects of legality and regular ‑
ity and provides little information on how to improve the cost‑effectiveness of 
monitoring.35 DG Agriculture and Rural 
Development: DSCG/2014/31 
(EFA layer), DSCG/2014/32 
(On‑the‑spot checks), 
DSCG/2014/33 (LPIS), 
DSCG/2014/39 (Geospatial aid 
applications); JRC (in 
conjunction with DG 
Agriculture and Rural 
Development): 
DS‑CDP‑ 2015 ‑06 (Technical 
guidance on the pro‑rata 
system for permanent 
grassland), DS‑CDP‑ 2015 ‑11 
(LPIS update) and 
DS‑CDP‑ 2015 ‑10 
(Management of layers).
36 DG Agriculture and Rural 
Development unit D.3 exists 
since January 2014.
38
Part III - The Commission’s LPIS monitoring improved but did 
not focus enough on LPIS performance
Action plans and financial corrections addressed LPIS 
shortcomings
60 
Action plans (see Figure  4) are a tool used by the Commission to address system ‑
ic LPIS weaknesses observed at Member State level. By the end of 2015, a total of 
seven joint LPIS action plans had been drawn up by the relevant Member States 
upon the Commission’s request. In addition to action plans instigated upon the 
Commission’s request, Member States or regions may also draw up action plans 
on their own initiative to remedy specific weaknesses. Ten such plans have been 
established since 2007.
61 
In contrast to the 2007 ‑2013 CAP , there is now an explicit legal basis for the action 
plans initiated upon the Commission’s request37. The regulation stipulates that 
action plans must include clear progress indicators and shall be established by 
the relevant Member State in consultation with the Commission. The most recent 
action plans – for Greece, Spain, France and England – contain such indicators. In 
its 2015 Annual Activity Report, the Commission considers that, because France 
has not met key commitments in the action plan, it should take measures to ad ‑
dress these issues and provide more detailed progress indicators. As a result of 
remedial actions carried out in 2014 and 2015, in Greece, the area registered as 
permanent pasture decreased from 3.6 million hectares to 1.5 million hectares, 
while in Spain the eligible agricultural land decreased from 18.4 million hectares 
to 15.6 million hectares38.
62 
Between 1999 and the end of 2015, the Commission took 49 decisions excluding 
from EU financing certain items of expenditure incurred by Member States under 
the European agricultural funds; the grounds included infringements of LPIS‑re ‑
lated provisions. Three decisions in 2015 concerned LPIS‑related infringements. 
In 2015, eight Member States39 faced financial corrections because of LPIS‑related 
deficiencies.
63 
In our 2014 Annual Report, we assessed whether a sample of six Member States40 
had addressed their LPIS‑related shortcomings in an effective and timely manner, 
and whether the Commission had applied financial corrections in compliance 
with the legislation. In all cases examined, financial corrections had either been 
imposed or conformity clearance procedures launched by the Commission.37 Article 41(2) of Regulation (EU) 
No 1306/2013, entering into 
force on 1 January 2014.
38 According to information 
provided by the Commission 
in its reply to box 7.8 of our 
2014 Annual Report.
39 Belgium, Bulgaria, Spain, 
France, Ireland, Lithuania, 
Portugal and the United 
Kingdom.
40 Bulgaria, Greece, Spain, Italy, 
Portugal and Romania.
39
Part III - The Commission’s LPIS monitoring improved but did 
not focus enough on LPIS performance
Overview of LPIS action plans and LPIS financial corrections since 2006Figure 4
Source:  European Court of Auditors based on European Commission data.
698
228 3145402
6855621193
5 10430278
108
35
3072Action plans instigated by the Commission: 
Greece (two), Bulgaria, Romania, Portugal, France and England
Action plans at the initiative of a Member State: Italy, the Netherlands, Sweden, Spain, Poland, NorthernIreland, Scotland, Lithuania, Austria and Ireland
Financial corrections: the /f_igures show the cumulative 
amount (in million euro) of /f_inancial corrections applied for the /f_inancial year 2006 and onwards, totalling 2 710 million euro.
11
40
Part III - The Commission’s LPIS monitoring improved but did 
not focus enough on LPIS performanceTable 264 
However, there had often been a rather long delay between the claim year con ‑
cerned and the calendar year in which the financial correction had been finally 
applied (see Table  2). The deadlines set in the regulation for the 2014 ‑2020 CAP 
were designed to streamline the conformity clearance procedure.
Examples of Commission decisions from 2015 excluding from EU financing certain 
expenditure of relevance to the LPIS incurred by the Member States under the 
European agricultural funds
Member State concerned Claim years concerned Number of Commission 
decision
Bulgaria 2009 Decision (EU) 2015/103
Spain 2006, 2007 and 2008 Decision (EU) 2015/103
France 2008 and 2009 Decision (EU) 2015/103
Lithuania 2007 and 2008 Decision (EU) 2015/103
Portugal 2009 Decision (EU) 2015/1119
Ireland 2008 and 2009 Decision (EU) 2015/1119
Source:  European Commission.
The reliability of the LPIS quality assessment results 
was undermined by weaknesses in its methodology 
and application
65 
Since 2010, following the identification of EU‑wide recurrent LPIS‑related weak ‑
nesses and the imposition of significant financial corrections on Member States 
(see paragraphs 60 to 64), the Commission introduced the LPIS quality assess ‑
ment (QA)41 as an obligatory tool with which Member States were asked to 
pro‑actively identify on an annual basis any weaknesses in the system and take 
remedial action where necessary. The QA is intended to be a systematic and con ‑
sistent review of agricultural area and certain related elements across the EU. It is 
based on an examination of a sample of between 500 and 1 250 reference parcels 
per LPIS. Currently, the QA framework comprises six quality elements (QEs) to 
be tested42 (see Annex II ). Changes to the QA methodology have been released 
annually, and multiple versions have sometimes been in circulation before a final 
version has been adopted. Methodological changes have varied significantly over 
time43.41 The legal basis for this 
exercise, previously Article 6(2) 
of Regulation (EC) 
No 1122/2009, is now Article 6 
of Regulation (EU) 
No 640/2014.
42 QE7 – ‘the rate of irregularities 
determined during 
on‑the‑spot checks’ – was 
removed with effect from the 
2015 QA exercise.
43 These changes included e.g. 
the revision or refinement of 
key concepts and definitions 
(e.g. ‘critical defects’ in ETS 5.1), 
revisions in the formula for 
calculating a QE (e.g. QE5 to 
QE7 in ETS 5.1), the addition of 
new components of a QE (e.g. 
QE1 b in ETS 5.3), removal of 
a QE (QE7 in ETS 6.0) or 
a change in the numbering of 
QEs (inversion of QE3 and QE4 
in ETS 6.0).
41
Part III - The Commission’s LPIS monitoring improved but did 
not focus enough on LPIS performance
66 
One concern consistently raised by Member States in our LPIS survey and con ‑
firmed by the experts involved in the peer review of the QA44 was the complexity 
of the QA methodology and the need for simplification. Our audit confirmed the 
difficulties faced by Member States in applying the LPIS QA methodology cor ‑
rectly and consistently (see B ox  11).
67 
We also identified issues in the QA’s sampling approach. To provide meaningful 
results, the LPIS QA sample should be representative of the overall population of 
agricultural parcels in each Member State / region where the QA is being carried 
out. The regulatory framework requires Member States to carry out the QA on the 
basis of a sample of zones and therein, a sample of LPIS reference parcels.44 ‘Peer review of the LPIS QA 
Framework’ conducted by 
Sytze de Bruin (Wageningen 
University) and Gábor Csornai, 
(Consultant V4.0), November 
2011.Box 11Examples of incorrect or inconsistent application of the QA methodology
In North Rhine‑Westphalia , after the 2014 QA parcel sample was established, 237 reference parcels (almost 
30 % of the sample size) were corrected by the paying agency in the framework of the systematic LPIS update 
exercise (including the examination of the new pictures received to carry out the QA). Only then were the QA 
tests carried out, based on the updated information in the system. The QA results were therefore biased.
The LPIS QA methodology requires paying agencies to carry out field visits to check the situation of parcels for 
which photo‑interpretation does not allow any conclusions to be drawn. However, only 17 of the 44 respond ‑
ents to our LPIS survey stated that they carried out such visits. Certain reference parcels in Ireland , Poland  
and Scotland  were not measured during the QA exercise, even though the measurement was indeed feasible 
and even required by the methodology.
QE4 was interpreted inconsistently. In Poland , the authorities did not consider that the parcels identifiable in 
the LPIS (i.e. digitised and given a unique identifier) could be assessed as having a critical defect. Since these 
conditions are prerequisites for inclusion in the LPIS, no parcel could possibly fail QE445.
In Ireland , Austria  and Germany  (Saarland  and North Rhine‑Westphalia ) we found a lack of proper segre ‑
gation of duties between the QA staff and the staff performing the LPIS update, creating the risk of these staff 
analysing their own update work in the QA.
45 The other Member States visited used various reasons for failing parcels for QE4 like multi‑parcels or multi‑polygons; no eligible area although 
MEA was greater than 0; an invalid perimeter or no boundaries making it impossible to locate the parcel; more than two missing boundaries.
42
Part III - The Commission’s LPIS monitoring improved but did 
not focus enough on LPIS performance
68 
In the QA 2010 to 2014 exercises, the zones were selected by the Member States 
while the reference parcels to be tested were selected by the Commission (JRC). 
During our visits, we identified weaknesses in the Member States’ sample selec ‑
tion for both zones and reference parcels, affecting the representativeness and 
comparability of results both between different Member States and over the 
years (see Box  12).Box 12Some weaknesses identified in QA sample selection from the 2010  to 2014 QA 
exercises
In all Member States visited during this audit, the QA zones were not selected from the population as a whole 
but rather drawn from the zones covered by remote sensing46, which only represented a small part of the 
territory of a Member State/region. Parcels not included in the remote sensing areas had no chance of being 
selected. Another issue was that the QA zones did not necessarily include all landscape types in the Member 
State/region (such as alpine pastures in Austria  or commonages in Ireland ).
In Ireland , the QA zones for 2013 and 2014 were not sufficiently dispersed, casting doubt on how they were 
selected.
46 Except where a Member State or region does not use remote sensing (Austria, Scotland).
69 
The Commission has striven to improve the efficiency of the QA sampling meth ‑
odology starting from the 2015 QA exercise, and to keep costs under control. As 
a result, the number of QA zones used for sampling has decreased considerably. 
The Commission ran two statistical tests to validate the representativeness of the 
new sampling methodology. These confirmed that, there is no significant differ ‑
ence in the sample representativeness between 2014 and 2015, although, in some 
cases, sample representativeness had been adversely affected by the limited 
number of QA zones and could therefore be improved subject to a cost/benefit 
assessment.
43
Part III - The Commission’s LPIS monitoring improved but did 
not focus enough on LPIS performance
The QA results were not sufficiently used to improve 
the quality of LPIS data
70 
One objective of the QA is to take remedial action when necessary. Member 
States are generally required to draw up remedial action plans in the absence of 
conformance with critical QEs. However, two of the audited Member States / re ‑
gions (Ireland and Scotland) consistently failed critical QEs but produced no 
remedial action plans. These were not isolated cases. For 2014, the Commission 
noted that, of the 20 Member States or regions that should have presented a re ‑
medial action plan based on their 2014 QA results, six (30 %) did not do so.
71 
The Commission is responsible for monitoring the QA results. It performed 
plausibility checks and contacted Member States and regions where it identified 
obvious errors or calculation errors in their QA reports. However, the Commission 
(DG Agriculture and Rural Development) did not subject incoming QA results to 
a more thorough examination as regards the reliability of the LPIS QA or causes 
of non‑compliance. A trend analysis of historical data for Member States and 
regions, an analysis of QA outliers, and an analysis by type of reference parcel 
were also lacking. Performing such analyses could help the Commission to spot 
unexplained deviations or trends in respect of the QEs.
72 
The Commission made a limited number of information visits to specific Member 
States or regions to discuss their QA results and clarify the methodology, and 
carried out some stand‑alone QA audits47. Some LPIS QAs were covered during 
the Commission’s regular area‑aid audits48, although the QA results were not 
explicitly considered before selecting which Member States to visit. From the 
results of the 2014 QA, the JRC prepared LPIS QA screening reports for five Mem ‑
ber States/regions49 audited by DG Agriculture and Rural Development in 2015; 
subsequently, the JRC was invited to participate in three corresponding missions. 
These information visits and audits were not sufficient to gain assurance as to the 
reliability of the QA results received annually for all LPISs.47 In 2014 for example in Ireland 
and the Netherlands.
48 In 2013, LPIS QA was covered 
only in Spain, Italy and 
Sweden. The 2014 audits 
covered the LPIS QA in 
Bulgaria, Ireland, Lithuania, the 
Netherlands and UK‑England.
49 BE‑Flanders, Denmark, Cyprus, 
Finland and UK‑Scotland.
44
 Conclusions and 
recommendations
73 
The information registered in LPISs – a crucial component of IACS – is the basis 
for correct area‑based payments to farmers. It is subject to certain requirements 
in the CAP regulations and should function as a tool for monitoring new CAP 
elements. It is therefore essential that the data in the LPIS is reliable in order to 
ensure that payments are legal and regular. Data reliability depends on effec ‑
tive and efficient updates, checks and monitoring by both the Commission and 
Member States.
74 
The audit addressed the question: ‘Is the Land Parcel Identification System (LPIS) 
well managed?’ We concluded that the LPIS is a useful tool to determine the eligi ‑
bility of agricultural land but its management could be further improved.
75 
LPISs, if properly updated and analysed, can make a significant contribution to 
preventing and detecting area‑related errors in aid applications. Over recent 
years our Statement of Assurance results showed that action plans and financial 
corrections addressed LPIS shortcomings in the Member States affected. How ‑
ever, some areas for improvement remain.
76 
In the LPIS update process, while the ortho‑imagery was mostly up‑to‑date, the 
audited Member States experienced difficulties in correctly determining the max ‑
imum eligible areas of reference parcels. This happened mainly in cases where 
ortho‑images alone did not make it possible to conclusively assess land eligibil ‑
ity e.g. for certain types of grassland (see paragraphs 14 to 29). In some of the 
LPISs additional information concerning ownership and lease rights was included 
in order to ensure that each parcel had been declared by the right farmer (see 
paragraphs 30 to 31). Member States did not evaluate the cost‑effectiveness of 
their LPISs in order to better design the related checks. This would help to design 
more efficient control systems and to support any future policy impact assess ‑
ments (see paragraphs 32 to 33).
45 Conclusions and recommendations 
Improving processes to increase LPIS data reliability and 
performance measurement
Recommendation 1 ‑  Improving processes to increase LPIS 
data reliability
Based on a quantified cost‑benefit analysis and an assessment of risks, the Mem ‑
ber States should, in the current CAP period, strengthen their efforts to increase 
LPIS data reliability based on timely and thoroughly conducted updates of the 
system. Given the complexity of pro‑rata assessment, the Member States using 
this option should, in the current CAP period, make further efforts to develop 
a pro‑rata catalogue with clear description and assessment criteria and to use 
complementary technical tools in order to increase the objectivity of ortho‑im ‑
agery analysis and ensure reproducibility. Member States should also consider 
the possibility of recording data on ownership and lease rights in their LPIS 
whenever feasible and cost‑effective.
Recommendation 2  – Measuring the cost‑effectiveness of 
implementing the LPIS
With the support of the Commission, the Member States should, in the cur ‑
rent CAP period, develop and set up a framework for assessing the cost of 
running and updating of their LPISs. This should enable the Member States to 
measure the performance of their LPISs and the cost‑effectiveness of system 
improvements.
77 
The LPIS provisions in the 2014 ‑2020 CAP legal framework have increased the 
number of requirements that must be checked by the Member States. The 
adaptation of LPISs for greening is progressing, although not yet complete, and 
the greening payment conditions can only partially be checked using the LPIS 
(see paragraphs 34 to 41). Other elements beneficial for the environment, such as 
landscape features protected under cross‑compliance, are not included in LPISs 
and, in cases where Member States had voluntarily decided to include them, we 
found cases of incorrect registration in the system (see paragraphs 42 to 43).
78 
Simplification is ongoing but remains a challenge – despite the benefit of useful 
tools such as geospatial aid applications –, as some provisions are either not used 
in practice (the 2 % stability threshold) or present significant implementation 
challenges (the 100 ‑tree rule or the new categories of eligible land). Current ef ‑
forts to simplify the LPIS are not yet complete (see paragraphs 44 to 55).
46 Conclusions and recommendations 
Tackling legal complexity more astutely
Recommendation 3  – Registering permanent environmental 
features more reliably
Member States should ensure that, using their LPISs, they reliably identify and 
register, and then effectively monitor, ecological focus areas, permanent grass ‑
land and new categories of land. They should also assess the cost versus benefits 
of including in their LPISs all landscape elements protected under cross‑com ‑
pliance or agri‑environmental schemes in order to further enhance the moni ‑
toring and protection of such elements beneficial for the environment and for 
biodiversity.
Recommendation 4  – Streamlining some LPIS‑related rules in 
the current legal framework
The Commission should re‑examine the current legal framework in order to 
simplify and streamline the LPIS‑related rules for the next CAP period, e.g. by 
re‑considering the need for the 2 % stability threshold and the 100 ‑tree rule.
79 
The Commission’s monitoring of legality and regularity in LPISs has improved 
compared to the previous CAP period. The Commission’s audit work is compre ‑
hensive, action plans are instigated as required and financial corrections are 
applied (see paragraphs 56 to 64).
80 
However, the Commission’s LPIS‑related guidance essentially addresses aspects 
of legality and regularity and does not focus on how to improve the overall 
effectiveness of the LPIS system. In particular, the Commission introduced the 
LPIS quality assessment to allow Member States to pro‑actively identify possible 
weaknesses in the system and to take remedial action where required. It is meant 
to add value to the LPIS but the reliability of the QA results is undermined by 
weaknesses in applying the methodology (possibly due to its complexity), but 
also by issues in the sampling approach (see paragraphs 65 to 69). In addition, 
the QA results are not used effectively to improve LPIS data, as remedial action 
plans are not always prepared. The Commission did not make sufficient use of QA 
results to foster improvement in the LPISs (see paragraphs 70 to 72).
47 Conclusions and recommendations 
Redefining the Commission’s focus on increasing the added 
value of the LPIS quality assessment for the current period
Recommendation 5  – Improving the representativeness of 
the QA samples
The Commission should, before the start of the QA exercise 2017, carry out 
a cost‑benefit analysis to determine whether the representativeness of QA sam ‑
ples could be improved so that a better coverage of the population of parcels in 
the LPIS can be achieved.
Recommendation 6  – Better monitoring of QA results
Starting in 2016, the Commission should improve the monitoring of QA results 
by analysing any inconsistencies in QA reporting, following them up, provid ‑
ing feedback to the Member States, and ensuring that remedial action plans are 
prepared and executed when needed. The Commission should also carry out 
a detailed annual trend analysis for each Member State and reference parcel type 
so that potential problems can be identified in good time.
This Report was adopted by Chamber I, headed by Mr Phil WYNN OWEN, Member 
of the Court of Auditors, in Luxembourg at its meeting of 7 September 2016.
 For the Court of Auditors
 Vítor Manuel da SILVA CALDEIRA
 President

48
 Annexes
LPIS layers as indicated in Article 5(1) and 5(2) of Regulation (EU) No 640/2014
 ο Areas taken up by arable land, permanent grassland and permanent pasture, or permanent crops (Article 4(1)(e) 
of Regulation No 1307/2013).
 ο Agricultural land with agri‑environment‑climate commitments (Article 28 (2) of Regulation No 1305/2013).
 ο Under Article 32(2)(b) of Regulation 1307/2013, areas which gave a right to payments in 2008 under the single 
payment scheme or the single area payment scheme laid down, respectively, in Titles III and IVA of Regulation (EC) 
No 1782/2003, and which:
(i) no longer comply with the definition of ‘eligible hectare’ as a result of the implementation of the 
Habitats Directive (92/43/EEC), the Water Framework Directive (2000/60/EC) and the Birds Directive 
(2009/147/EC),
(ii) for the duration of the relevant commitment by the individual farmer, are afforested pursuant to 
Article 31 of Regulation (EC) No 1257/1999, Article 43 of Regulation (EC) No 1698/2005 or Article 22 of 
Regulation (EU) No 1305/2013, or are under a national scheme, the term of which complies with Arti ‑
cle 43(1), (2) and (3) of Regulation (EC) No 1698/2005 or Article 22 of Regulation (EU) No 1305/2013, 
or
(iii) for the duration of the relevant commitment by the individual farmer, are set aside pursuant to Ar ‑
ticles 22, 23 and 24 of Regulation (EC) No 1257/1999, Article 39 of Regulation (EC) No 1698/2005 or 
Article 28 of Regulation (EU) No 1305/2013.
 ο Information determining the MEA for:
(i) area‑related rural development measures,
(ii) the basic payment scheme,
(iii) the single area payment scheme,
(iv) redistributive payment,
(v) payments for agricultural practices beneficial for the climate and the environment,
(vi) payments for areas with natural constraints,
(vii) payments for young farmers,
(viii) voluntary coupled support,
(ix) crop‑specific payments for cotton,
(x) the small farmers scheme,
(xi) POSEI (measures for the outermost regions)
(xii) the Aegean islands.Annex I
49 Annexes 
 ο Information giving the location and size of EFAs.
 ο Information justifying the application of specific provisions for:
(i) mountain areas and other areas facing significant natural or other specific constraints, as referred to 
in Article 32 of Regulation (EU) No 1305/2013,
(ii) Natura 2000 areas covered by Directive 2000/60/EC,
(iii) agricultural land authorised for cotton production pursuant to Article 57 of Regulation 
(EU) No 1307/2013,
(iv) areas naturally kept in a state suitable for grazing or cultivation, as referred to in Article 4(1)(c)(iii) of 
Regulation (EU) No 1307/2013,
(v) areas designated by Member States for the regional and/or collective implementation of EFAs in ac ‑
cordance with Article 46(5) and (6) of Regulation (EU) No 1307/2013,
(vi) areas notified to the Commission in accordance with Article 20 of Regulation (EU) No 1307/2013,
(vii) areas covered with environmentally‑sensitive permanent grasslands and covered by the Habitats 
Directive or the Birds Directive,
(viii) further sensitive areas, as referred to in Article 45(1) of Regulation (EU) No 1307/2013,
(ix) areas designated by the Member States in accordance with Article 48 of Regulation (EU) No 
1307/2013.Annex I
50 Annexes 
QA exercise 2015  – QEs by conformance class
First conformance class – to 
assess the quality of the LPISQE1 The correct quantification of maximum eligible area (MEA)
QE2 The proportion and distribution of reference parcels where the MEA takes ineligible 
areas into account or does not take agricultural area into account
QE3 The occurrence of reference parcels with critical defects1
Second conformance class – to 
identify possible weaknesses in 
the LPISQE4 The categorisation of reference parcels where the MEA takes ineligible areas into ac -
count, where it does not take agricultural area into account or reveals a critical defect2
QE5 The ratio of declared area to MEA inside the reference parcels
QE6 The percentage of reference parcels which have been subject to change, accumulated 
over the years
Source: Article 6 of Regulation (EU) No 640/2014 and JRC portal3.
1 Note: QE4 before 2015.
2 Note: QE3 before 2015.
3 See https://marswiki.jrc.ec.europa.eu/wikicap/index.php/LPISQA_Legacy/ETS/Decisions .Annex II
51 Reply of the  
Commission
Executive summary
I
The Commission considers that LPIS makes a significant contribution in preventing and reducing the levels of errors 
in the aid schemes to which it applies.
III First indent
LPIS is the cornerstone of the Integrated Administrative and Control System. It is a tool which allows the majority of 
the administrative checks to be carried out. It helps to prevent, detect and correct errors in the early stages of the 
aid application processing. Moreover, the LPIS together with the GSAA strengthen the error prevention upstream 
and promote timely error rectification. 
Notwithstanding the above, it is the Member States’ responsibility to keep their LPIS up ‑to‑date and properly 
interpret the ortho ‑imagery. The LPIS Quality Assessment (QA) methodology as developed by the Commission helps 
Member States to identify weaknesses related to the erroneous processing or photo ‑interpretation of imagery and 
take corrective actions. 
III Third indent
The Commission's monitoring of the LPIS QA results has been strengthened since the audited period. 
IV (a)
This recommendation is for the Member States.
Regarding the relevance, appropriateness and usefulness of checking through the LPIS the issue of land at the 
farmer’s disposal, please see Commission's reply to paragraph 30.
IV (b)
The Commission accepts the recommendation to support Member States through facilitating exchanges of best 
practices and by undertaking a feasibility study.
IV (c)
This recommendation is for the Member States.
IV (d)
The Commissions accepts the recommendation. 
All LPIS ‑related rules will be reviewed and if considered necessary, revised for the new CAP post 2020.
IV (e)
The Commission accepts the recommendation. 
The monitoring of sample representativeness is part of a continuous process.
Reply of the Commission 52
IV (f)
The Commission accepts the recommendation and has already started implementing it.
For the claim years 2014 and 2015 Member States have been provided with feedback on their LPIS QA reporting in 
the form of official letters, including remarks on required but not provided remedial actions.
All remedial actions have been analysed and in respect of those which were deemed inadequate or insufficient, 
revised remedial actions were requested. A specific risk assessment is in development and used by the Commission 
as part of its monitoring tasks as a mean to identify Member States which may have issues with the correct applica ‑
tion of the LPIS QA methodology, including identifying the problems in the system and addressing them through 
appropriate remedial actions.
Part I 
13
The LPIS is the cornerstone of the IACS and the key instrument to control the majority of direct payments. A reliable, 
up‑to‑date and accurate LPIS is of great importance for the fulfilment of the policy objectives. In addition, it may be 
useful for Member States to study the cost effectiveness of their system in order to improve performance. 
20
As regards the cases of delays in new ortho ‑imagery being entered into the LPIS, the Commission has recom ‑
mended to the Member States on numerous occasions to have their LPIS updated before the start of the application 
process1. 
22
The Commission considers that the LPIS QA results, stemming from a statistically representative sample, show 
a level of overstatement below 2% at the EU ‑level. A correct establishment of the maximum eligible area for every 
reference parcel in LPIS is not realistic without enormous costs2. 
1 This is explicitly mentioned in section 4.4 of document DS ‑CDP ‑2015 ‑11‑ FINAL ‑ LPIS Update (‘ the aim is to make the new images ready and available 
to be used in the geo-spatial aid application process ’). In addition, it is explained that processing of ortho ‑imagery should normally not take more 
than 3 months.
2 Analysis of the reported LPIS QA results estimates the average significant MEA overestimate by reference parcels (QE1b ‑/LIB) for the European 
Union as follows: 2013: 0.93%, 2014: 1.14%, 2015: 0.64%. The data quantify system bias (QE1a) as 2013: +0.41%, 2014: ‑ 1.16%, 2015: ‑0.34%. The 
number of inspected reference parcels was 39700, 42550 and 41300 respectively.
Reply of the Commission 53
Box 2 – Examples of incorrect assessment of MEA which could have been identified by 
photo ‑interpretation 
As regards the examples of incorrect assessment of the maximum eligible area provided by the Court the Commis ‑
sion does not contest them. However, these particular cases in the examples are not representative of other LPIS's 
as a whole. The various LPIS's across the EU are different in many aspects and the characteristics of the agricultural 
areas in the EU are also very different. 
23
The Commission has recommended to Member States to carry out rapid field visits (RFV) in case of doubts on the 
conclusiveness of the photointerpretation on eligibility. As mentioned in paragraph 25, RFV come at cost and there ‑
fore the Commission has provided for guidance, platforms and workshops to make the use of photo ‑interpretation 
more efficient.
29
The Technical Guidance on the pro rata system for permanent grassland, DS ‑CDP ‑2015 ‑06 final provides for best 
practices to support Member States in the implementation of the pro rata.
In addition, the approach of the LIDAR (Light Detection And Ranging) technology used by Spain has been shared as 
a potential tool at the Workshop on Control and Management of Agricultural Land in IACS on 23 – 25 May 2016.
30
The EU legislation does not require complementing the LPIS with information on whether the parcels are at the 
farmer's disposal. Systematic cross ‑checks with information on whether or not the parcels are at the farmer's dis ‑
posal are not required. The Commission recommends to Member States to carry out on ‑the‑spot checks in case of 
doubts in relation to the farmer’s disposal of land.
32
Under shared management, Member States decide, within the existing legal framework, on the most cost ‑effective 
way to implement the CAP . The Commission has organised several workshops to disseminate best practices includ ‑
ing topics such as how to identify and qualify agricultural land with a view to improving cost effectiveness.
33
The Commission is aware of the cost of the main functions of LPIS and in proposing EU legislation takes it into 
account. Beyond that there is a great diversity of LPIS and Member States choose various implementation options. 
Under shared management, it is for Member States to make their policy choices taking into account the cost ‑effec ‑
tiveness of their LPIS. 
Reply of the Commission 54
Part II  
38
Through the LPIS guidance the Member States are made aware of the requirement and modalities to geo ‑localise 
permanent grassland (at the smallest possible level). Through LPIS QA, in particular QE 2, Member States have to 
assess the quality of this classification and take appropriate remedial actions when necessary. 
Box 8 – Weaknesses in the monitoring of permanent grassland
When analysing the results of the LPIS QA it is recognised that the classification of agricultural land is one of the 
main points where remedial actions by Member States are taken. 
See also Commission's reply to paragraph 38.
40
Although the Commission recommends to the Member States to include all potential EFA's in the EFA layer of the 
LPIS, in the context of the simplification initiative, the Commission has lightened the minimum requirements in 
terms of completeness of the EFA ‑layer. In section 5.10 of the relevant guideline on the completeness of the EFA ‑
layer (DSCG/2014/31 FINAL REV 1), it is stated that, as a minimum requirement, the EFA ‑layer needs to include, after 
verification and before payment, at least all the EFAs declared which are stable in time.
44
Simplification of the CAP is an on ‑going process respecting three main principles: No changes to the basic act (sta ‑
bility of policy); for the benefit of the farmer; and ensuring a sound financial management. The Commission con ‑
firms that in its view simplification does concern the LPIS.
45
The introduction of the geo ‑spatial aid application is a simplification for farmers at application stage. Similarly, the 
2% stability threshold aims at avoiding that the paying agencies unnecessarily and too frequently up ‑date the refer ‑
ence parcels in the LPIS for minor variations in measured area. Finally, the rule related to the maximum tree density 
(so‑called 100 ‑tree rule) also aims at providing clear, simple and straightforward assessment criteria for the eligibil ‑
ity of parcels with scattered trees.
46
The Commission's data indicate that 14 Member States and 4 German Länder and Flanders had full coverage of the 
territory already in 2015, even though it is only mandatory to have at least 25% coverage as of 2016.
Reply of the Commission 55
48
The geo ‑spatial aid application is also a clear simplification for farmers whereby, in case of stable and reliable infor ‑
mation provided to them, they could simply ‘click and confirm’ the validity of the pre ‑established information at the 
application stage.
50
In order to determine the eligible area for permanent grassland, Member States could use either the pro ‑rata or 
the maximum tree density (the so ‑called 100 ‑tree rule). Under both possibilities, Member States should analyse in 
advance and determine species that are considered grazable that will not be excluded from the eligible area. The 
increased administrative burden stems directly from the Member States' choices.
The maximum tree density and the pro ‑rata system aim at providing the national administrations with simpler and 
straightforward means to assess the maximum eligible area of reference parcels that contains scattered trees as it 
would be burdensome to delineate every single ineligible tree.
52
The LPIS is a powerful tool to check stable elements of eligibility of agricultural parcels but there are indeed some 
eligibility conditions, such as maintenance activities, which are more difficult to control through the LPIS. In LPIS 
there is a difference in treatment between unmaintained land (i.e. lack of agricultural activity) and abandoned land. 
Both are ineligible, however, unmaintained land could be only a temporary phenomenon, while abandoned land is 
more likely to be permanent ineligible.
53
See Commission’s replies to paragraph 23 and 33.
55
The Commission considers that the simplification referred to in point b is beneficial for both beneficiaries and the 
paying agencies. 
Reply of the Commission 56
Part III  
56
LPIS QA is a yearly process, the ultimate objective of which is to improve the quality and reliability of the LPIS, by 
analysing detected technical weaknesses and to taking remedial actions to address them.
59
The Commission includes best practice and cost ‑effectiveness considerations when drafting guidance documents 
and in the technical guidance in close cooperation with the Member States.
64
Financial corrections are imposed in relation to financial years, so applications submitted in a given claim year are 
paid in the subsequent financial year. Moreover, the financial corrections normally include the expenditure incurred 
in the 24 months preceding the launching of enquiry. The 24 ‑month rule allows covering longer periods and thus 
extending the protection of the EU budget.
65
The core item of inspection of the LPIS QA is the LPIS reference parcel which acts as the container for agricultural 
area potentially subject to an aid application. 
The LPIS QA is intended to be a systematic and consistent review of the various systems independently developed 
by the Member States. It aims at finding possible weaknesses of these systems, so that Member States can remedy 
them on their own initiative.
Draft versions of the methodology have indeed been circulated and iterated (allowing Member States to react) in 
order to ensure that all valid comments from Member States are gathered and duly considered before a final version 
is released.
Most of the methodological revisions have been triggered by the changes introduced in the legislation and by the 
specific requests from LPIS stakeholders (Member States) to better reflect their particular LPIS implementation 
modes.
66
The LPIS QA methodology is in essence simple. It compares the recorded information with what is measured during 
this exercise and then the results are analysed.
The apparent complexity of the current guidance is generated by i) the introduction of processes options requested 
by Member States to accommodate their different LPIS implementation strategies and ii) a robust documentation 
format based on ISO19100 ‑series standards. 
Reply of the Commission 57
Box 11 – Examples of incorrect or inconsistent application of the QA methodology
Irrespective of the potential issue in North Rhine ‑Westphalia the Commission does not systematically consider the 
LPIS QA as being biased when a certain number of parcels of the sample population were updated in the framework 
of the systematic LPIS update exercise in the period between sampling and actually executing the assessment. Such 
a situation may reflect an effective LPIS update management.
The Commission organised a number of sessions during LPIS/OTSC workshops in 2014 and 2015 to bring the need 
for field visits to the attention of the Member States.
The four ‑eye principle introduced in ETS 6.0 stipulates explicitly the need of an independent operator.
Common Commission’s reply to paragraphs 67 and 68
In 2015, a change was introduced in the sampling strategy and the image provision aimed to address this issue. As 
from 2015 exercise the sampling of zones for the QA and the selection of the sample of reference parcels (RP) to be 
analysed is done by the Commission and independently from the Member States. The same methodology is now 
run for all LPIS, which ensures both the representativeness of the population and consistency all over the EU and 
over time.
Box 12 – Some weaknesses identified in QA sample selection from the 2010 to 2014 QA 
exercises
As the remote sensing zones were mostly selected on a random basis, in principle all reference parcels had an equal 
chance to be selected. Nevertheless, the responsibility of selecting the reference parcels has been shifted to the JRC 
to ensure a better and unbiased sample selection.
70
A remedial action plan is expected when the assessment of the findings reveals specific weaknesses that require 
a dedicated intervention. A decision for such plan should be taken only after the assessment of the LPIS QA findings.
When analysing the LPIS QA the Commission detected cases with failures in critical QE and despite this no remedial 
actions were set up by the Member States. This has been brought to their attention during the LPIS workshops and 
as from 2015 these cases are closely followed up.
Common Commission’s reply to paragraphs 71 and 72
From 2015 a complete follow ‑up of the reports is in place for the period covered by the audit. However from 2014, 
QA reports and remedial actions provided by the Member States were analysed.
The focus of the Commission has been on the reliability and consistency of the figures provided in the reports. 
A trend analysis will be carried out during the intensified monitoring of the LPIS QA if it is considered appropriate. 
Since the QA methodology has developed during the years, an overall trend analysis is not straightforward as the 
data are not completely comparable.
The Commission intends to make implementation support visits to some Member States in order to assist them with 
improving the quality of their LPIS.
Reply of the Commission 58
The Commission was aware that the LPIS ‑QA results for claim year 2011 were at that time not the most reliable as it 
was the first trial year.
Conclusions and recommendations
76
The EU legislation does not require complementing the LPIS with information on whether the parcels are at the 
farmer's disposal. Systematic cross ‑checks with information on whether or not the parcels are at the farmer's dis ‑
posal are not required. The Commission recommends to Member States to carry out on ‑the‑spot checks in case of 
doubts in relation to the farmer’s disposal of land.
Recommendation 1 ‑  Improving processes to increase LPIS data reliability 
This recommendation is for the Member States.
Recommendation 2 – Measuring the cost ‑effectiveness of implementing the LPIS
The Commission accepts the recommendation to support Member States through facilitating exchanges of best 
practices and by undertaking a feasibility study.
78
The 2% stability threshold aims at avoiding that the paying agencies unnecessarily and too frequently up ‑date the 
reference parcels in the LPIS for minor variations in measured area. Finally, the rule related to the maximum tree 
density (so ‑called 100 ‑tree rule) also aims at providing clear, simple and straightforward assessment criteria for the 
eligibility of parcels with scattered trees.
Recommendation 3 – Registering permanent environmental features more reliably 
This recommendation is for the Member States.
Recommendation 4 – Streamlining some LPIS ‑related rules in the current legal 
framework
The Commissions accepts the recommendation. 
All LPIS ‑related rules will be reviewed and if considered necessary, revised for the new CAP post 2020. 
Reply of the Commission 59
80
As regards the LPIS QA sent by Member States to the Commission, where relevant, formal feedback is requested 
from the Member States including clarifications on the content (lack of) remedial action plans. Furthermore, general 
results and observations are presented to and discussed with the Member States during the yearly workshops. In 
2016, observations were also made during direct payment committee to increase awareness of Member States’ rep ‑
resentatives of the real advantage of the LPIS QA exercise for the improvement of their LPIS. (cf. also Commission’s 
reply to paragraph 70 and 22).
The sampling approach is continuously monitored by the Commission.
Recommendation 5 – Improving the representativeness of the QA samples 
The Commission accepts the recommendation.
The monitoring of sample representativeness is part of a continuous process.
Recommendation 6 – Better monitoring of QA results 
The Commission accepts the recommendation and has already started implementing it.
For the claim years 2014 and 2015 Member States have been provided with feedback on their LPIS QA reporting in 
the form of official letters, including remarks on required but not provided remedial actions.
All remedial actions have been analysed and in respect of those which were deemed inadequate or insufficient, 
revised remedial actions were requested. A specific risk assessment is in development and used by the Commission 
as part of its monitoring tasks as a mean to identify Member States which may have issues with the correct applica ‑
tion of the LPIS QA methodology, including identifying the problems in the system and addressing them through 
appropriate remedial actions. 

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Event Date
Adoption of the Audit Planning Memorandum/Start of audit 3.6.2015
Official sending of draft report to Commission (or other auditee) 13.6.2016
Adoption of the final report after the adversarial procedure 7.9. 2016
Commission’s (or other auditee’s) official replies received in all languages 13.9.2016
A Land Parcel Identification System (LPIS) is an IT system 
based on photographs of agricultural parcels used to check 
payments made under the Common Agricultural Policy 
(CAP) of approximately 45.5 billion euro in 2015. We 
concluded that the LPIS is a useful tool for determining the 
eligibility of agricultural land but its management could be 
further improved. We identified some weaknesses in LPIS 
processes affecting the Member States’ ability to reliably 
check the eligibility of land. We found that Member States 
had made progress in upgrading their LPISs to meet the 
2014-2020 CAP requirements. However, LPISs had not yet 
been completely adapted for greening. The Commission’s 
LPIS monitoring improved but did not focus enough on LPIS 
performance.
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