Report from the Commission to the Council on the application of the system of cross-compliance (under Article 8 of Council Regulation (EC) No 1782/2003 establishing common rules for direct support schemes under the common agricultural policy and establishing certain support schemes for farmers)
Date: 2007-03-29
Institutions: European Commission
Subjects: EU aid, aid to agriculture, reform of the CAP, regulation of agricultural production

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 29.3.2007 
COM(2007) 147 final 

REPORT FROM THE COMMISSION TO THE COUNCIL 

on the application of the system of cross-compliance 

(under Article 8 of Council Regulation (EC) No 1782/2003 establishing common rules  
for direct support schemes under the common agricultural policy and  
establishing certain support schemes for farmers) 

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REPORT FROM THE COMMISSION TO THE COUNCIL 

on the application of the system of cross-compliance 

(under Article 8 of Council Regulation (EC) No 1782/2003 establishing common rules  
for direct support schemes under the common agricultural policy and  
establishing certain support schemes for farmers) 

1. 

INTRODUCTION 

The cross-compliance system is a major component of the 2003 common agricultural policy 
(CAP)  reform.  Cross-compliance  creates  a  link  between  the  full  payment  of  support,  and 
compliance with  certain rules relating  to agricultural  land  and to  agricultural production and 
activity in the areas of the environment, public, animal and plant health, animal welfare and 
good agricultural and environmental condition. This link is expressed in concrete terms in the 
possibility, if the rules are not respected, of full or partial reductions of certain EU agricultural 
payments.  The  reductions  shall  be  based  on  the  severity,  the  extent,  the  permanence,  the 
repetition and the intentionality of the non-compliance. 

Cross-compliance  has  two  objectives.  The  first  is  to  contribute  to  the  development  of 
sustainable agriculture. This is achieved through the respect by the farmer of the rules relating 
to  the  relevant  aspects  of  cross-compliance.  The  second  objective  is  to  make  the  CAP  more 
compatible with the expectations of society at large. There is now a growing body of opinion 
that  agricultural  payments  should  no  longer  be  granted  to  farmers  who  fail  to  comply  with 
basic  rules  in  certain  important  areas  of  public  policy.  The  Commission  is  convinced  that 
achieving these two objectives will help to ensure the CAP's future. 

Member States have now to apply this system for all direct payments – decoupled or coupled – 
under the first pillar of the CAP1. They have also to apply it to eight measures of the second 
pillar of the CAP2.  

The start-up phase has given rise to discussion on a number of issues and the sensitivity of this 
topic is in itself an indication that cross-compliance is not just a question of presentation. This 
should be regarded as a positive development, as cross-compliance should lead to improve the 
sustainability of the CAP and the level of public support for this policy. There is therefore no 
question of watering down this concept. Instead, every effort should be made to improve its 
acceptance by all actors, for the benefit of all. 

As  the  farmers  are  at  the  heart  of  the  system  and  their  acceptance  of  cross-compliance  is 
central  to  its  success,  it  is  very  important  to  see  things  from  their  perspective.  Cross-
compliance may indeed represent a challenge as it often results in a rather bulky set of rules, 
which  were  previously  implemented  independently  of  each  other  but  are  now  gathered  in  a 
single list touching on areas as different as environment, public health and animal health and 
welfare. The crucial element, the possibility of reduced payments, is also a matter of concerns. 

1 
2 

See Annex I to Council Regulation (EC) No 1782/2003. 
See Article 51 of Council Regulation (EC) No 1698/2005. 

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For  the  national  administrations,  the  introduction  of  cross-compliance  has  also  been  a 
challenge.  They  had  in  particular  to  define  in  detail  and  communicate  to  farmers  in  an 
understandable way the requirements and standards to be fulfilled, to set-up the management, 
control  and  reduction  system  and  to  ensure  smooth  coordination  between  all  the  bodies 
involved. 

It is important to distinguish between issues arising from the Community framework and those 
linked to the national implementation of this framework. In this respect, it should be noted that 
subsidiarity  is  one  of  the  underlying  principles  of  cross-compliance.  The  EU  framework 
provides  that  the  requirements  and  standards  should  address  the  local  risks  and  constraints, 
and  this  means  that  they  differ  between  Member  States  or  regions.  The  EU  framework  also 
encourages the wide use of pre-existing national management systems, which means that the 
organisation  of  control  systems  also  differs  between  Member  States.  At  the  same  time, 
however,  there  is  a  need  to  ensure  a  level  playing-field  with  regard  to  cross-compliance  for 
farmers across the EU. This is ensured by means of a common framework which must remain 
compulsory, as regards both the definition of requirements and standards farmers have to fulfil 
and the management, control and reduction system. Striking the appropriate balance between a 
common EU framework, on the one hand, and local specific situations, on the other, is one of 
the most important challenges faced by the system. 

The Commission is aware of these sensitivities on the part of those concerned and the present 
report  will  mainly  concentrate,  therefore,  on  proposing  immediate  solutions  to  the  problems 
identified  so  far.  The  Commission  is  funding  a  number  of  studies  on  the  implementation  of 
cross-compliance  by  Member  States.  These  are  still  ongoing  and  no  definitive  conclusions 
have been reached as yet. It is therefore too early to contemplate changes to the scope of cross-
compliance but these will be addressed in the context of the "health check". 

2. 

CROSS-COMPLIANCE AS DEFINED AT EU LEVEL 

The  scope  of  cross-compliance  (the  rules  with  which  the  farmer  has  to  comply)  comprises 
two  components:  the  "statutory  management  requirements"  (SMRs)  and  "good  agricultural 
and  environmental  condition"  (GAEC).  The  GAEC  includes  two  types  of  element:  farmers' 
compliance  with  a  set  of  standards  relating  to  four  issues,  and  an  obligation  on  the  Member 
State to maintain the proportion of its agricultural area under permanent pasture. 

•  The  introduction  of  SMRs  under  cross-compliance  does  not  create  new  obligations  for 
farmers,  since  the  legislation  in  question  and  its  enforcement  rules  existed  independently 
for  some  time  previously  and  cross-compliance  reductions  apply  without  prejudice  of  the 
independent  system  of  penalties  established  by  the  specific  legislation.  It  may  however 
contribute significantly to the improved implementation of this legislation, in particular by 
raising  awareness  among  farmers.  14  of  the  18  Community  acts  listed  as  SMRs  are 
Directives which, by their very nature, leave discretion to Member States as to the means to 
apply in order to achieve the objectives laid down therein. To some extent, this influences 
also their enforcement through cross-compliance.  

•  When cross-compliance entered into force the GAEC standards, as such, were new at least 
to  those  farmers  who  had  not,  as  beneficiaries  of  rural  development  agri-environmental 
measures or less-favoured area payments, previously to apply good farming practices. The 
Member States have to define minimum requirements for all standards on the basis of the 
framework set up in Annex IV of Council Regulation (EC) No 1782/2003, except those that 
are not relevant to the national context. From a survey of Member States the Commission's 

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services  are  aware  of  certain  problems  with  the  definition  and  the  extent  of  minimum 
requirements by the Member States. These problems will be followed up with the Member 
States and solutions will have to be found. 

3. 

OBSERVATIONS ON THE APPLICATION OF THE CROSS-COMPLIANCE SYSTEM 

3.1. 

Summary of data on the application of the system 

The  lively  character  of  the  discussions  on  cross-compliance  is  not  the  only  indication  that, 
despite  the  constraints  outlined  above,  the  system  is  actually  being  implemented  on  the 
ground.  The  Commission  also  has  confirmation  of  this  in  the  form  of  data  received  from 
23 Member  States  on  controls  and  reductions.  These  data  (for  2005)  may  be  summarised  as 
follows: 

–  on-the-spot  checks  (240 898  in  total)  were  carried  out  on  4.92%  of  farmers  affected  by 
cross-compliance.  The  rate  for  the  Member  States  applying  full  cross-compliance  (4.4%) 
stems from the specific control rate for identification and registration of cattle (5 or 10% of 
holdings). The rate for Member States covered by the single area payment scheme (SAPS) 
(5.7%), which apply only the GAECs, arises from the fact that in most Member States joint 
checks were carried out for cross-compliance and eligibility; 

–  reductions  were  applied  for  11.9%  of  farmers  subject  to  on-the-spot  checks:  this  rate  is 
higher  for  Member  States  applying  full  cross-compliance  (16.4%)  than  for  the  other 
Member States (6.1%) as the latter had only to check for respect of the GAEC. Across the 
EU, total reductions applied amounted to € 9.84 million; 

–  in Member States applying full cross-compliance3, most (71%) detected instances of non-
compliance related to the identification and registration of cattle, while the remaining cases 
mainly concern the GAEC (13%) and the Nitrates Directive (10%); 

–  most  reductions  (68%  overall  –  up  to  98%  in  some  Member  States)  were  applied  at  the 
minimum level of 1% of direct payments. Some 14% were applied at a 3% level and 12% 
at a 5% level. 

3.2. 

Issues raised by Member States 

In early 2006, Commission services and Member States had an exchange of views on cross-
compliance  (on  the  basis  of  a  questionnaire  on  the  subject)  in  the  framework  of  the 
Management Committee for Direct Payments. Member States explained issues that had arisen 
in the first year of implementation, which can be summarised as follows: 

•  General.  The  management  of  the  system  was  felt  in  general  to  be  burdensome.  It  was 
difficult to determine the practical elements with which farmers have to comply and which 
have to be subsequently controlled. It was not always easy to communicate the new rules to 
the farmers. Historical information was also lacking. 

•  Reception  among  farmers.  Awareness-raising  among  farmers  was  hampered  by  the 
volume  and  technical  nature  of  the  information  on  cross-compliance.  Farmers  were 
sometimes confronted with new obligations. They also were under the impression that they 

3 

In order not to distort the figures, this does not include Member States only applying the GAEC. 

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were faced with the threat of a "double sanction": one under cross-compliance and another 
under the specific legislation.  

•  Organisation of the system. It was sometimes difficult to reconcile the use of the existing 
management  and  control  system  and  the  EU  legal  provisions.  Specific  constraints  and 
problems  arose  from  decisions  Member  States  had  made  as  regards  the  organisation  of 
controls, e.g. too many or too few competent control authorities. 

•  Sampling and control rate. The population subject to controls was known too late to allow 
for the checking of certain requirements. It was suggested that rules for a possible random 
selection should be specified. The control rate could be higher under certain circumstances 
(same  population  covered  by  several  control  authorities  with  a  rate  of  1%  each,  specific 
control  rates  to  apply,  e.g.  bovines,  etc.).  In  particular,  the  specific  control  rates  to  be 
applied under sectoral legislation could pose organisational problems. 

•  On-the-spot  checks  and  reporting.  The  rules  were  not  clear  enough  as  regards  the 
appropriate time to carry out on-the-spot checks, what should be checked during the visit 
and the number of visits required. It was felt that checks were long, especially if the farm 
was split over several sites, and involved the participation of the farmer. Some requirements 
were difficult to check. Control reports were lengthy and not always easy to understand.  

•  Calculation  of  reductions.  The  number  and  range  of  requirements  meant  that  the 
calculation  of  reductions  was  difficult  and  not  easy  for  the  farmers  to  understand.  It  was 
hard  to  define  the  notions  of  "severity",  "extent",  "permanence",  "repetition"  and  overall 
"intentionality".  It  was  also  felt  that  the  application  of  the  "repetition"  was  also  too 
automatic. There were risks of discrepancies between Member States. In practice, there was 
little scope for exempting minor instances of non-compliance from reductions, which made 
those concerned less receptive to the system.  

3.3. 

Initial assessment of the audits carried out by the Commission 

In 2005 and 2006, Commission services carried out 13 audits on the implementation of cross-
compliance by ten Member States. The main findings are as follows: 

•  Information  given  to  farmers.  Information  was  given  to  farmers  through  booklets, 
internet  material  and  training  sessions.  Issues  covered  included  cross-compliance 
obligations,  controls  and  the  calculation  of  reductions  (the  information  on  the  latter  was 
sometimes rather general). This information was sometimes provided too late. 

•  Designation  of  the  competent  control  authorities.  A  small  number  of  Member  States 
have  designated  the  Paying  Agency  as  the  only  competent  control  authority  (CCA)  for 
cross-compliance. In the other cases, the Paying Agency usually plays a coordinating role. 
The  involvement  of  the  specialised  control  bodies  ensures  a  high  level  of  expertise  but 
raises coordination problems. It was also found that the CCAs sometimes delegate the on-
the-spot checks to other bodies (public or private). 

•  Selection  of  the  control  samples  and  risk  analysis.  Difficulties  have  arisen  where  the 
population covered by the CCA is too small to allow a proper risk analysis, and also where 
the CCA is responsible for checking compliance with many requirements. In many cases, 
few specific risk criteria are used even if the information is available. Finally, the existence 
of differing control rates under cross-compliance gave rise to certain difficulties. 

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•  Elements  of  on-the-spot  checks  and  reports.  The  main  difficulties  found  as  regards 
checks  were  with  SMR  2  (groundwater),  SMRs  1  and  5  (wild  birds  and  habitat),  SMR 4 
(nitrates), and SMRs 6 and 8a (animal identification and registration) for sheep, goats and 
pigs. Problems were found in the harmonisation of reports, the description of the nature and 
extent of checks performed, and the evaluation of detected cases of non-compliance. 

•  Application of reductions. Some Member States had already established reduction levels, 
thus leaving no scope for an evaluation by the controller, while other Member States only 
provide guidelines for calculating the reductions. Some matrices are unlikely ever to lead to 
reductions of more than 1%. Also, in many of the Member States that were visited, minor 
instances  of  non-compliance  are  exempted  from  reductions.  Finally,  detected  instances  of 
non-compliance outside the 1% control sample are not always followed up. 

These findings will be assessed in the framework of the clearance of accounts procedure for 
EAGF expenditure. 

4. 

IMPROVEMENTS TO THE SYSTEM 

4.1. 

Development  and  simplification  of  the  management,  control  and  reduction 
system 

Issues regarding the management, control and reduction systems have been identified on the 
basis of the information set out above. The Commission services have already taken initiatives 
to  help  the  Member  States  to  implement  cross-compliance  and  seven  guidance  documents 
have been issued since 2005. They have also organised exchanges to enable Member States to 
share "best practices" and compare their experience of cross-compliance implementation. The 
Commission will continue to encourage such discussions, especially on: 

– 

– 

– 

– 

the  possible  use  of  bottlenecks  for  controls,  e.g.  conducting  controls  at  the  level  of 
dairies or slaughterhouses, which could lead to facilitate on-farm checks, 

the systems of reductions (e.g. applying points systems), 

the information provided to farmers, 

the fact that some farmers are at greater risk of reductions than others. 

The Commission is prepared to take further action without delay to tackle remaining questions 
which can be resolved at EU level. In this connection, the following issues will be addressed 
in discussions at Council or Commission level. 

4.1.1.  Tolerance for minor cases of non-compliances, new de minimis rule 

In certain cases non-compliances found during checks may not justify a reduction under cross-
compliance4. However, the current rules do not explicitly provide for any margin of discretion 
for  the  treatment  of  these  minor  infringements.  In  line  with  the  principle  of  proportionality 
Member  States  should  be  allowed  not  to  pursue  instances  which  would  not  trigger  the  3% 

4 

For  instance  animals  kept  for  farming  purposes  shall  be  identified  in  accordance  with  Community 
animal health rules. Losing an ear tag or a cattle-passport does not mean an automatic sanction provided 
that  animals  remain  identified  by  other  elements  (second  ear  tag  or  holding  register).  In  this  case  the 
national authorities may not consider it as non-compliance liable to a reduction under cross-compliance. 

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reduction  foreseen  in  case  of  negligence,  which  may  in  certain  cases  be  reduced  to  a  1% 
minimum reduction. Nevertheless, in these cases, a warning letter should be sent to the farmer 
indicating  that  remedial  action  is  necessary.  These  cases  will  be  followed  up  and  would  be 
taken into account in case of repetition of non-compliance. In order to determine a margin of 
tolerance  for  the  purpose  of  implementing  such  exemptions,  a  generalisation  of  the  points 
system, which already applies in some Member States, may be examined. 

Applying  reductions  to  very  low  initial  amounts  may  also  be  seen  as  unjustified  and 
burdensome for the administration. Therefore a de minimis rule should be established allowing 
an exemption from applying reductions under cross-compliance, which fall below a threshold 
of around € 50. This would exempt from the immediate 1% reductions farmers receiving less 
than € 5 000. However the warning letter and follow-up as set out above should also apply in 
these cases.  

In  both  cases  remedial  action  must  be  followed  up  outside  the  regular  1%  control  sample. 
However this should not lead to the introduction of a new control layer. 

The  application  of  these  rules  would  be  without  prejudice  to  the  enforcement  of  sanctions 
established under the specific legislation. 

4.1.2.  Harmonisation of control rates 

Where the specific legislation for certain sectors fixes a minimum control rate, it is this rate 
that should be applied rather than the 1% minimum rate laid down for cross-compliance. As 
mentioned by certain Member States, the existence of differing control rates might be making 
it  more  difficult  to  organise  controls  for  cross-compliance.  The  Commission  intends  to 
introduce in the relevant Commission regulation a single control rate, of 1% minimum, for on-
the-spot checks for cross-compliance. Nevertheless, any instances of non-compliance detected 
in the course of on-the-spot checks under the sectoral legislation would have to be reported, 
and followed up under cross-compliance. This 1% minimum control rate is without prejudice 
to the follow-up checks in the context of the tolerance for minor cases of non-compliances and 
the de minimis rule. 

Under  current  Commission  legislation,  if  on-the-spot  checks  reveal  a  significant  degree  of 
non-compliance, the number of such checks to be carried out in the following control period is 
increased.  These  follow–up  checks  concern  all  requirements  and  standards  for  which  the 
competent  control  authority 
the  Member  State's 
administrative  structure,  the  increased  control  rate  may  concern  several  areas  of  cross-
compliance. It would be preferable, however, to focus the increase of controls only on the area 
of  risk.  The  Commission  therefore  intends  to  change  the  rules  so  that  the  increase  in  the 
control  rate  is  limited  to  the  particular  area  in  which  a  high  degree  of  non-compliance  was 
found. 

is  responsible  and,  depending  on 

4.1.3.  Advanced notice of on-the-spot checks 

There  is  no  provision  in  the  current  legislation  regarding  the  prior  announcement  of  on-the-
spot  checks  for  cross-compliance.  Nevertheless,  where  joint  checks  are  carried  out  for 
eligibility  and  cross-compliance,  the  principle  of  unannounced  checks  for  the  former  has 
placed a de facto constraint on checks for the latter. Relaxing this restriction for area eligibility 
checks  would  improve  the  coordination  of  controls  without  jeopardising  their  effectiveness. 
The  Commission  therefore  will,  for  SPS,  SAPS  and  cross-compliance  (including  the  eight 
rural  development  measures),  create  a  possibility  to  give  notice  of  checks  up  to  14 days  in 

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advance  provided  that  the  purpose  of  the  checks  is  not  jeopardized.  The  possibility  of 
extending  this  rule  to  other  schemes  will  be  further  examined.  However,  controls  on  the 
identification  and  registration  of  animals  (for  eligibility  or  for  cross-compliance)  and  on 
compliance  with  feed  and  food  law,  animal  health  and  animal  welfare  rules  will  remain  in 
principle unannounced due to the mandatory requirements of EU legislation. 

4.1.4.  Timing and elements of on-the-spot checks and reports 

The timing of on-the-spot checks is not fixed in the current legislation, and this has given rise 
to a number of questions from Member States. The Commission foresees to clarify the rules to 
make it clear that the national authorities are required to identify the period of the year during 
which most, or the  more  representative,  obligations are checked. Most of the checks will be 
carried  out  during  this  period.  The  remaining  obligations  will  be  checked  within  the  regular 
1% minimum sample at different times of the year. 

Furthermore the Commission envisages to make the necessary changes in order to allow on-
the-spot checks (like for eligibility checks), to be carried out on only half of the parcels instead 
of the whole farm. 

Finally,  rules  should  be  clarified  to  ensure  that  the  farmer  receives  the  control  report  at  the 
latest three months after the checks. 

4.1.5. 

Improved selection of the control sample 

Current legislation on on-the-spot checks does not allow for farms to be selected partly on a 
random basis. As random sampling has proved useful in the context of eligibility checks, the 
Commission  intends  to  modify  the  rules  to  include  a  random  element  for  cross-compliance 
too. 

4.1.6. 

Improved information to farmers 

It  is  essential  that  farmers  are  properly  informed  of  the  specific,  concrete  requirements  they 
have to respect under cross-compliance. The Commission intends to clarify of the current rules 
with regards to the information Member States are obliged to provide to farmers.  

4.1.7.  Timetable  for  implementation  of  new  or  changed  requirements  under  the  present 

scope of cross-compliance 

Experience  has  shown  that  it  is  not  always  easy  to  farmers  to  implement  new  requirements 
introduced  under  cross-compliance.  This  has  been  taken  into  account  for  the  current 
requirements  with  a  3-year  phasing-in  of  the  SMRs.  The  Commission  envisages  to  maintain 
this phasing-in principle by establishing a realistic timetable for the inclusion of any new or 
changed requirements under cross-compliance. 

4.2. 

Taking into account the Farm Advisory Systems 

Member States had to set up, by 1 January 2007, a farm advisory system (FAS) covering at 
least  the  requirements  and  standards  of  cross-compliance.  The  Commission  services  see  this 
advisory  system  as  fundamental  to  enhancing  the  acceptance  of  cross-compliance  by  the 
farmers. Indeed, a number of the problems that arose during the start-up period are linked to 
difficulties that farmer had in understanding and implementing cross-compliance obligations. 
As a farmer receiving advice is more likely to understand and therefore comply with his cross-

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compliance obligations, his participation in the FAS could be taken into account as a factor in 
the risk analysis. The Commission intends to clarify the rules accordingly. 

4.3. 

Taking  into  account  the  certification  systems  for  the  management  of  cross-
compliance 

A number of farmers are currently participating in quality certification schemes which usually 
involve  a  number  of  audits  being  made  by  the  certification  body.  In  some  cases,  cross-
compliance on-the-spot checks are perceived by farmers as an unnecessary new administrative 
burden because they cover the same issues as certain standards already certified under private 
schemes. It seems appropriate to look for synergies between certification schemes and cross-
compliance on-the-spot checks, provided that the certification schemes are officially approved 
and  relevant  to  cross-compliance.  The  Commission  therefore  envisages  to  adapt  the  rules  in 
order  to  allow  the  competent  authorities  to  use  data  concerning  certified  farmers  for  risk-
analysis purposes for the sample selection of farmers to be checked. 

4.4. 

Simplification of the "10-month rule" 

The  so-called  "10-month  rule"  laid  down  in  Article 44(3)  of  Council  Regulation  (EC) 
No 1782/2003 proved difficult to manage by Member States and has a disproportionate impact 
on the land market. This rule – which obliges the farmer to keep at his disposal for 10 months 
the  parcels  declared  to  activate  entitlements  for  the  single  payment  scheme  (SPS)  –  poses  a 
number of management problems. A proposal will be made to address this issue properly for 
both  the  SPS  and  the  SAPS.  In  addition,  the  responsibility  of  the  transferor  vis-à-vis  cross-
compliance  obligations  in  cases  where  land  is  transferred  in  the  course  of  the  year  will  be 
clarified.  

4.5. 

Phasing-in of the introduction of SMRs for Member States applying the SAPS 

Under Council Regulation (EC) No 2012/2006, Member States applying the SAPS will have 
to implement the SMRs as part of cross-compliance as from 2009. Experience with the other 
Member States has shown that setting up this element of cross-compliance was facilitated by a 
3-year phasing-in period. A proposal is envisaged to apply the same 3-year phasing-in period 
for  the  Member  States  applying  the  SAPS  –  this  period  would  start  in  2009  for  all  except 
Bulgaria and Romania, for whom it would start in 2012. 

5. 

CONCLUSIONS 

In the light of the evaluation set out in this report, the Commission, still in 2007, intends to: 

a. 

b. 

provide  further  information  on  the  implementation  of  cross-compliance  by  Member 
States; 

make a proposal to the Council or submit draft rules to the Management Committee 
for Direct Payments to: 

– 

– 

– 

provide for a phased-in introduction of the SMRs for Member States applying 
the SAPS, 

introduce provisions for simplifying the "10-month rule", 

make  improvements  for  tolerance  for  minor  cases  of  non-compliances  and 
introduce a new de minimis rule, 

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– 

– 

– 

– 

– 

harmonise control rates, 

introduce advance notice of on-the-spot checks, where possible, 

clarify the timing and the elements of on-the-spot checks and reports, 

improve the selection of the control sample, also with regards to the FAS and 
the certification systems, 

and improve the information to farmers. 

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