Biodiversity on farmland : CAP contribution has not halted the decline. Special report No 13, 2020.
Date: 2021-01-23
Institutions: European Court of Auditors
Subjects: EU strategy, agricultural holding, audit, biodiversity, common agricultural policy, conservation of resources, ecosystem, environmental impact, intensive farming, report, rural development

EN 

2020 

13 

Special Report  Biodiversity on farmland: 
CAP contribution has not 
halted the decline 

 
Contents 

Executive summary 

Introduction 

Declining farmland biodiversity is a major threat 

International and EU action to halt biodiversity loss 

Audit scope and approach 

Observations 

Gaps in design of the EU biodiversity strategy, its coordination 
with the CAP and its monitoring 

EU biodiversity strategy lacks rigour in relation to target 3a, and related 
indicators show weaknesses 

No EU strategy for conservation of genetic diversity 

The Commission overestimates how much it spends on biodiversity 

Most CAP funding has little positive impact on biodiversity 

Most direct payments do not maintain or enhance farmland biodiversity 

The cross-compliance sanctions scheme has no clear impact on farmland 
biodiversity 

The potential of greening to improve biodiversity is underdeveloped 

Some rural development schemes have potential for improving 
farmland biodiversity 

Agri-environment-climate, Natura 2000 and organic farming measures have 
most potential to maintain or enhance farmland biodiversity 

Less demanding agri-environment-climate measures have higher 
participation rates 

Arable farmers are less likely to commit to biodiversity-relevant agri-
environment-climate measures 

Result-based schemes have positive effects but are rare 

Few rural development indicators focus on results and many have not been 
updated recently 

2 

Paragraph 

I-VIII 

01-13 

01-08 

09-13 

14-18 

19-73 

19-37 

20-27 

28-30 

31-37 

38-60 

39-40 

41-50 

51-60 

61-73 

62-64 

65-67 

68-69 

70 

71-73 

 
 
3 

74-82 

Conclusions and recommendations 

Annexes 

Annex I – Main audit work at Member State level 

Annex II – Biodiversity indicators 

Terms and abbreviations 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I In Europe, the number and variety of species on farmland – “farmland biodiversity” 
– has declined over many years. Since 1990, for example, populations of farmland 
birds and grassland butterflies have declined by more than 30 %. 

II The Commission adopted a biodiversity strategy in 2011, in the aim of halting the 
loss of biodiversity and the degradation of ecosystems by 2020, and restoring them as 
far as possible. In particular, it committed to increasing the contribution of agriculture 
and forestry to maintaining and enhancing biodiversity. It did so in the context of an 
international commitment to this objective stemming from ratification of the United 
Nations Convention on Biological Diversity by all Member States and the EU itself. 

III For the 2014-2020 period, the Commission planned to spend 8.1 % of the EU 
budget (€86 billion) on biodiversity; 77 % of this amount (€66 billion) coming from the 
common agricultural policy (CAP). The EU’s role in protecting and enhancing 
biodiversity on farmland is crucial because the EU sets environmental standards 
through legislation and co-finances most of Member States’ agricultural spending. 

IV The purpose of this audit was to assess the contribution made by the CAP to 
maintaining and enhancing biodiversity. We examined the EU’s efforts to achieve its 
2020 biodiversity targets, and we provide recommendations to feed into the current 
legislative preparations for the 2021-2027 CAP and the implementation of the new EU 
biodiversity strategy post-2020. 

V We assessed whether the EU designed its biodiversity strategy and the CAP legal 
framework for 2014-2020 to better conserve biodiversity. We also examined how the 
Commission has monitored and evaluated progress towards the 2020 agriculture 
target of its biodiversity strategy. Finally, we assessed the degree to which EU and 
Member State action has contributed to achieving the 2020 agriculture target. 

VI We found that the formulation of the agriculture target and actions in the EU 
biodiversity strategy to 2020 makes it difficult to measure progress. We also found a 
lack of coordination between EU policies and strategies, one result of which is that 
they do not address the decline in genetic diversity. Lastly, we found that the 
Commission’s tracking of CAP spending for biodiversity is unreliable. 

 
 
5 

VII Where known, the effect of CAP direct payments – 70 % of EU agriculture 
spending – on farmland biodiversity is limited. Some direct payment requirements, 
notably greening, and cross-compliance, have potential to improve biodiversity, but 
the Commission and Member States have favoured low-impact options. The EU’s rural 
development instruments have greater potential than direct payments for maintaining 
and enhancing biodiversity. However, Member States relatively seldom use high-
impact rural development measures such as result-based and “dark green” schemes.  

VIII We recommend that the Commission: 

(1) 

Improves coordination and design for the post-2020 EU biodiversity strategy – to 
this end also tracking expenditure more accurately; 

(2)  Enhances the contribution of direct payments to farmland biodiversity; 

(3) 

Increases the contribution of rural development to farmland biodiversity; and 

(4)  Develops reliable indicators to assess the impact of the CAP on farmland 

biodiversity. 

 
 
 
 
6 

Introduction 

Declining farmland biodiversity is a major threat 

01 The global decline in biodiversity is widely recognised. In 2019, the 
Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services 
(IPBES) warned that the decline is at rates unprecedented in human history – around 
one million animal and plant species worldwide are currently threatened with 
extinction1. In January 2020, the World Economic Forum classified the loss of 
biodiversity and collapse of ecosystems as one of the top five threats facing the 
world2, in both likelihood and impact. 

02 The 2019 State of the Environment report from the European Environment 
Agency (EEA)3 found that agricultural intensification remains one of the main causes of 
biodiversity loss and ecosystem degradation in Europe. In many areas of Europe, 
intensification has transformed formerly diverse landscapes, consisting of many small 
fields and habitats, into uniform unbroken terrain managed with large machines and a 
highly reduced work force (see Figure 1). This has led to a decline in the abundance 
and diversity of natural vegetation and, as a result, animals4. A 2017 study from 
Germany to measure total insect biomass, with traps deployed in 63 nature protection 
areas to provide information on the status and trend of local species, estimated a 
seasonal decline of 76 %, and a mid-summer decline of 82 %, in flying insect biomass 
over 27 years5. While the quantification put forward in this report has been 
challenged, other studies support the conclusion on the overall trend6. 

1 

IPBES: “Global assessment report on biodiversity and ecosystem services”, 2019. 

2  World Economic Forum: “Global Risks Report”, 2020. 

3  EEA: “The European environment – state and outlook 2020”, 2019. 

4 

IPBES: “Regional assessment report on biodiversity and ecosystem services for Europe and 
Central Asia”, 2018. 

5  Hallmann et al.: “More than 75 percent decline over 27 years in total flying insect biomass 

in protected areas”, PLoS ONE 12, 2017. 

6  Early, C.: “Insect armageddon – the devil is in the detail”, Ecologist, 3 November 2017. 

 
 
                                                       
Figure 1 – Decline in farmland biodiversity due to intensification of land 
use 

7 

Source: ECA. 

03 Farmland bird populations are considered to be a good indicator of changes in
farmland biodiversity because birds play a significant role in the food chain and are 
found in many varied habitats. The most recently published aggregated bird 
population index shows that bird species have declined since 1990; most strikingly, the 
EU Farmland Bird Index (FBI) shows a 34 % decline among 39 species common on 
farmland. In the same period, the Forest Bird Index increased by 0.1 % – suggesting 
that agriculture is a significant driver for biodiversity loss (see Figure 2). 

Figure 2 – Common farmland and forest birds – EU population Index 

100

90

80

70

60

50

40

30

20

10

)
0
0
1
=
0
9
9
1
(
x
e
d
n

i

n
o

i
t
a

l

u
p
o
P

Common forest birds + 0.1 %

(34 species)

Common farmland birds − 34 %

(39 species)

0
1990  1992  1994  1996  1998  2000  2002  2004  2006  2008  2010  2012  2014  2016  2018 

Source: ECA, based on Eurostat data (2020). 

 
 
 
 
8 

04 Like birds, butterflies occur in a number of habitats and respond rapidly to 
changes in environmental conditions. The Commission Staff Working Document, 
accompanying the mid-term review of the biodiversity strategy to 2020, states that 
butterflies are representative of many other insects7. The latest European Grassland 
Butterfly Index is from 2017. It shows that total numbers of 17 typical butterflies have 
declined by 39 % since 1990, indicating a considerable loss of grassland biodiversity 
(see Figure 3), though the situation has stabilised since 2013. Fourteen Member 
States8 contributed to the most recent butterfly monitoring data. 

Figure 3 – European Grassland Butterfly Index 

− 39 % (2017)

100
100
90
90
80
80
70
70
60
60
50
50
40
40
30
30
20
20
10
10
0
0

)
0
0
1
=

0
9
9
1
(

x
e
d
n

i

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o
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o
P

l

Source: ECA, based on EEA data (2019). 

05 Natura 2000 is a network of core breeding and resting sites for rare and 
threatened species, and some rare natural habitat types in the EU. The most recent 
reporting cycle for Natura 2000 and the related Habitats and Birds Directives, 
measuring the situation of species and habitats of EU interest during 2013-2018, 
shows that the situation had deteriorated in comparison to 2007-2012: the proportion 

7  Commission: Commission Staff Working Document – “EU assessment of progress in 
implementing the EU biodiversity strategy to 2020 (2/3)”, SWD(2015) 187 final, 
accompanying the Report from the Commission to the European Parliament and the 
Council – “The Mid-term Review of the EU Biodiversity Strategy to 2020”, COM(2015) 
478 final, p. 20. 

8  Belgium, Estonia, Finland, France, Germany, Ireland, Lithuania, Luxembourg, Netherlands, 

Portugal, Romania, Slovenia, Spain and Sweden. 

 
 
 
                                                       
 
 
 
 
9 

of habitats with an “unfavourable” conservation status rose from 69 % to 72 %9. The 
EEA reported in 201910 that agriculture was by far the main source of pressure on 
Natura 2000 protected grassland habitats (see Figure 4). 

Figure 4 – Key pressures on grassland habitats in Natura 2000 areas 

Source: ECA, based on EEA data (2019). 

06 The situation of biodiversity in Europe varies, and Member States therefore face 
different challenges. For example, in Bulgaria and Romania, which are still widely 
considered to have a rich biodiversity (due to, among other things, more traditional 
non-intensive farming practices and smaller farms), some studies have concluded that 
it was sufficient to maintain the existing biodiversity status11. In other Member States, 
such as the Netherlands and Germany, where intensive farming is far more common, 
scientists see a need to re-establish biodiversity in areas where species and rich natural 
habitats have disappeared in recent decades12. 

9  https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-the-eu/article-17-

national-summary-dashboards/conservation-status-and-trends. 

10  EEA: “The European environment – state and outlook 2020”, 2019. 

11  Sutcliffe et al.: “Harnessing the biodiversity value of central and eastern European 

farmland”, Diversity and Distributions, 21, 2015. 

12  Erisman et al.: “Agriculture and biodiversity: a better balance benefits both”, AIMS 
Agriculture and Food, 1(2), 2016; BfN: “Agriculture Report: Biological diversity in 
agricultural landscapes”, 2017. 

 
 
 
                                                       
10 

07 In March 2020, the Commission published an evaluation report on the impact of 
the CAP on habitats, landscapes and biodiversity13. According to the evaluation, an 
overall impact assessment was not possible owing to the lack of suitable monitoring 
data. The evaluation concluded that Member States have not made sufficient use of 
the available CAP instruments to protect semi-natural features, in particular grassland, 
or to ensure that all semi-natural habitats that could be farmed are eligible for direct 
payments. It also found that Member States could have used a wider range of CAP 
measures to support the co-existence of agriculture with biodiversity. In addition, the 
design and funding of agri-environment-climate measures (AECMs), which provide 
support for intensive cropping farms, has been insufficiently attractive to bring about 
the necessary management changes to improve biodiversity performance. 

08 The influence of the CAP on the situation of farmland biodiversity is not known 
for the EU as a whole. However, a study published in 201914 on the situation in Czechia 
provided evidence that agriculture markedly intensiﬁed after the country joined the EU 
in 2004, and that farmland bird populations have declined since the same date. The 
Danish Farmers Association has found, meanwhile, that the steep decline in insect 
populations described in two German studies from 2017 (see paragraph 02) and 
201915 was most strongly connected with the withdrawal of obligatory set-aside from 
the CAP rules in 200916. The European Economic Community introduced set-aside in 
1988 to help reducing the large and costly surpluses produced in Europe under the 
guaranteed price system of the CAP and to deliver environmental benefits. Farmers 
were required to leave a proportion of their land out of intensive production. 

13  Alliance Environnement: “Evaluation of the impact of the CAP on habitats, landscapes, 

biodiversity”, November 2019. 

14  Reif et al.: “Collapse of farmland bird populations in an Eastern European country following 

its EU accession”, Conservation Letters, 2019. 

15  Seibold et al.: “Arthropod decline in grasslands and forests is associated with drivers at 

landscape level”, Nature, 2019. 

16  Deter, A.: “Insektenrückgang: Dänischer Bauernverband sieht Zusammenhang mit EU-

Agrarpolitik”, TopAgrar Premium, 2019. 

 
 
                                                       
11 

International and EU action to halt biodiversity loss 

09 The EU and the Member States each signed the United Nations Convention on 
Biological Diversity (CBD) in 1992 and 1993. The European Council (Council) approved 
the CBD in 199317. All parties to the CBD, including the EU and its Member States, 
committed to the “Aichi” biodiversity targets in 2010, setting the global framework for 
priority action on biodiversity for the period to 2020. The main coordination 
mechanism in the EU is the Council’s Working Party on International Environment 
Issues (Biodiversity). The 2030 Agenda for Sustainable Development and its 17 goals 
(SDGs), adopted by the UN in 2015, also provided new momentum for biodiversity. 
The main “Aichi” targets and SDGs relevant to farmland biodiversity are shown in 
Figure 5. 

Figure 5 – Main 2020 Aichi targets and 2030 SDGs relevant to agriculture 

Aichi Target 7

By 2020 areas under agriculture, aquaculture and forestry should be managed sustainably, 
ensuring conservation of biodiversity.

Aichi Target 13

By 2020, the genetic diversity of cultivated plants and farmed and domesticated animals 
and of wild relatives, including other socio-economically as well as culturally valuable 
species, should be maintained, and strategies should have been developed and 
implemented  for minimizing genetic erosion and safeguarding their genetic diversity.

Sustainable  Development Goal  15

Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably 
manage forests, combat desertification, and halt and reverse land degradation and halt 
biodiversity loss.

Source: ECA, based on UN publications. 

10 To meet its commitments under the CBD, in 1998 the Commission adopted a 
Communication on a European Biodiversity Strategy. In 2001, it produced its first 
action plan, which it updated in 2006, and then replaced in 2011 with an EU 

17  Council Decision of 25 October 1993 concerning the conclusion of the Convention on 

Biological Diversity (93/626/EEC). 

 
 
 
                                                       
12 

biodiversity strategy for the period to 2020. The Council (in 2011)18 and the European 
Parliament (in 2012)19 endorsed the strategy, which contains six targets. Target 3 
focuses on increasing the contribution of agriculture and forestry to maintaining and 
enhancing biodiversity. Target 3a, the agriculture target, includes a general 
commitment, three actions and five sub-actions (see Figure 6). 

Figure 6 – Agriculture target 3a of the EU biodiversity strategy to 2020 
and related actions 

Source: ECA, based on Commission information. 

11 At the Commission, the Directorate-General for Environment (DG ENV) has 
overall responsibility for proposing and implementing environmental legislation and 
policies. The Directorate-General for Agriculture and Rural Development (DG AGRI) 
deals with agricultural legislation and policies. Member States are required to develop 
and oversee efforts to achieve the target. 

12 As the current biodiversity strategy is to lapse this year, the Commission 
announced in its European Green Deal that it envisaged issuing a new strategy for the 
period to 2030. The new strategy was published in May 2020. It outlines general 
principles and sets the scene for the CBD Conference of Parties (COP15). To give 
practical shape to the new strategy, the Commission plans to issue follow-up actions 
and measures in 2021. 

18  EU Biodiversity Strategy to 2020 – Conclusions adopted by the Council (Environment) on 

21 June 2011 (ST11978/11). 

19  European Parliament resolution of 20 April 2012 on our life insurance, our natural capital: 

an EU biodiversity strategy to 2020 (2011/2307(INI)). 

 
 
 
                                                       
Figure 7 – International agreements and EU action on biodiversity 

International  agreements

EU actions

13 

1979

1992

1993

1998

2001

2010

2011

2015

CBD ratification: Multilateral 
environmental agreement (196 parties)

CBD Strategic Plan for Biodiversity 2011-
2020, including Aichi Biodiversity Targets

UN 2030 agenda for sustainable 
development, including Sustainable 
Development Goal 15 – Life on Land

Birds directive: Protect all of the 500 wild bird species 
naturally occurring in the European Union

Habitats directive: Conserve wide range of rare, 
threatened or endemic animal and plant species and 
habitat types
MacSharry CAP reform, introducing mandatory agri-
environmental schemes

Commission Communication on a European Biodiversity 
Strategy: The Commission stressed the need to 
anticipate, prevent and attack the causes of significant 
reduction or loss of biodiversity at source

EU biodiversity action plan: Target: halt loss of 
biodiversity in the EU by 2010 and take action to restore 
habitats and natural ecosystems

EU Biodiversity Strategy to 2020: Target: halt loss of 
biodiversity and degradation of ecosystem services in the 
EU by 2020, and restore them in so far as is feasible, 
while stepping up the EU contribution to averting global 
biodiversity loss

2020

CBD COP15:  Develop post-2020 
framework (planned)

EU Biodiversity Strategy to 2030

Source: ECA. 

13 The EU sets environmental and agricultural standards through EU legislation and 
supporting financially the agricultural sector. For the 2014-2020 period, the 
Commission reports that it has allocated 8.1 % of the EU budget (€86 billion) to 
biodiversity. The Commission mentions in its Statement of budget estimates 2020 that 
biodiversity funding from the common agricultural policy (CAP) will be €66 billion 
(77 % of biodiversity spending) over the entire 2014-2020 period. 

 
 
 
 
 
14 

Audit scope and approach 

14 The purpose of this audit was to assess the role of the CAP in maintaining and 
enhancing biodiversity under Target 3a of the EU biodiversity strategy to 2020. We 
chose this topic because of the high rate of biodiversity loss in Europe, the major role 
played by agriculture in that loss, the large share the CAP takes of the EU budget and 
recent negative assessments of the way the strategy, and the agriculture target in 
particular, have been implemented in the EU. This special report complements our 
special report on Natura 200020. 

15 Our aim was to provide recommendations to feed into the current legislative 
preparations for the 2021-2027 CAP, the new EU biodiversity strategy to 2030, and 
discussion and decision-making at the COP15. The content of the new strategy was not 
part of the audit, neither was the degree to which the EU has made progress on its 
international commitments on biodiversity. The audit also does not cover pollinators, 
as we will issue a separate report on this topic. The estimated direct yearly 
contribution of insect pollinators to European agriculture is €15 billion21. 

16 The audit covered the design, implementation, results and monitoring of EU 
actions to halt biodiversity loss on farmland in the EU. We focused on those 
components of the EU and national biodiversity strategies that are relevant to 
agriculture, and on their implementation by means of various instruments, notably the 
CAP. We looked mainly at the current programming period (2014-2020), though for 
comparative purposes we also examined the design, implementation and results of 
analogous CAP instruments from the previous period (2007-2013). Lastly, we took 
account of the Commission’s legislative proposals for the CAP for the post-2020 
period. 

20  See ECA special report 1/2017: “More efforts needed to implement the Natura 2000 

network to its full potential”. 

21  Potts et al., “Status and trends of European pollinators. Key findings of the STEP project”, 

14 January 2015. 

 
 
                                                       
15 

17 The main audit question was: “Has the CAP contributed positively to maintaining 
and enhancing biodiversity?” In order to answer this question we assessed: 

o  whether the EU designed its biodiversity strategy and the CAP legal framework for 

2014-2020 to better conserve biodiversity, and how the Commission has 
monitored and evaluated progress towards the 2020 agriculture target of its 
biodiversity strategy; 

o  whether direct payments have had a demonstrable positive impact during the 

2014-2020 CAP period; and 

o  whether CAP rural development action in 2014-2020, notably through AECMs, has 

focused on biodiversity. 

18 We collected audit evidence through: 

o 

o 

o 

o 

o 

a review of data and documents, including scientific, strategic, legislative, policy 
and guidance documents relating to farmland biodiversity in the EU and in a 
sample of Member States and regions; 

interviews with staff of five Commission directorates-general (Agriculture and 
Rural Development, Environment, Eurostat, the Joint Research Centre, Research 
and Innovation) and the European Environment Agency, representatives of NGOs 
(BirdLife Europe, COPA-COGECA, IEEP Brussels, Eurogroup for Animals) and of 
national and regional authorities, farmers’ organisations and other entities; 

visits to five Member States with different biodiversity, agricultural and landscape 
profiles (Cyprus, Germany, Ireland, Poland and Romania); 

farm visits and discussion with 78 farmers in 14 Member States (see Annex I); 

a survey of national and regional authorities of nine other Member States/regions 
(for details see Annex I). 

In addition, in October 2019, we organised a panel discussion on farmland biodiversity 
with scientific, policy and administrative experts in this area. The panel helped us to 
verify and develop our audit findings. Staff from DG AGRI and DG ENV observed the 
discussion. 

 
 
 
 
16 

Observations 

Gaps in design of the EU biodiversity strategy, its coordination 
with the CAP and its monitoring 

19 We examined whether the 2020 agriculture target in the EU biodiversity strategy 
is specific, measurable, achievable, relevant and time-bound and whether the EU’s 
action is consistent with it. We also checked whether the CAP 2014-2020 legislation is 
aligned with the EU biodiversity strategy to 2020 and national initiatives, and whether 
the Commission’s tracking gives reliable information about EU biodiversity spending. 

EU biodiversity strategy lacks rigour in relation to target 3a, and related 
indicators show weaknesses 

20 As shown in Figure 6, the EU strategy consists of targets and actions. It was set 
for a ten-year period, whereas the EU budget and agricultural policy framework follow 
a seven-year policy cycle. The 2011 impact assessment accompanying the 
Commission’s EU biodiversity strategy to 2020 stated that the “indicative” agriculture 
target (3a) would need “to be translated in concrete terms in the design of the CAP 
reform, to deliver on the 2020 biodiversity target”22. The performance of CAP 
measures for 2014-2020 are measured in relation to three objectives, including 
sustainable management of natural resources and climate action, with a focus on 
greenhouse gas emissions, biodiversity, soil and water23. 

22  Commission: “Impact Assessment Accompanying the Communication—Our Life Insurance, 

Our Natural Capital: an EU Biodiversity Strategy to 2020”, SEC(2011) 540 final. 

23  Article 110(2) of Regulation (EU) No 1306/2013 on the financing, management and 

monitoring of the common agricultural policy. 

 
 
                                                       
17 

21 The Commission reported in its 2015 mid-term review of the biodiversity strategy 
to 2020 that there had been no significant progress, especially towards Target 3 on 
agriculture (target 3a) and forestry (target 3b), and that “greater efforts” were needed 
to meet the deadlines (see Figure 8). Recent scientific findings24 also confirm, as 
reported in paragraphs 03 to 05, that there has been no measurable overall 
improvement towards Target 3 since 2015, and that it will not be met by 2020. 

Figure 8 – Mid-term assessment of the six targets of the biodiversity 
strategy 

Fully implement the 
Birds and Habitats 
Directives

Increase the contribution of 
agriculture to maintaining  and 
enhancing biodiversity

Ensure the sustainable use of fisheries 
resources and achieve good 
environmental status

Help avert global 
biodiversity loss

Target 1

Target 2

Target 3a

Target 3b

Target 4

Target 5

Target 6

Maintain and restore 
ecosystems and their 
services

Currently on track 

Increase the contribution of forestry to 
maintaining and enhancing biodiversity

Help combat invasive alien 
species

Progress but at an insufficient 
rate

No significant progress towards the 
target

Source: ECA, based on Commission 2015. 

22 The Commission tabled its CAP legislative proposals for the post-2020 period in 
2018. One of the nine specific objectives is for the CAP to contribute to biodiversity 
protection, better ecosystem services and the preservation of habitats and 
landscapes25. The schedule for the new biodiversity strategy to 2030 in place at the 
time of the audit (a general outline in 2020, followed by an action plan in 2021) made 
it difficult to take the new strategy into account when designing CAP measures 
covering the EU. However, it will be available for Member States to use when 
developing their own CAP strategic plans in 2021. 

24  See e.g. Langhout, W.: “The EU Biodiversity Strategy to 2020. Progress report 2011-2018”, 
2019; Simoncini et al.: “Constraints and opportunities for mainstreaming biodiversity and 
ecosystem services in the EU’s Common Agricultural Policy: Insights from the IPBES 
assessment for Europe and Central Asia”, Land Use Policy, Volume 88, 2019; EEA: “The 
European Environment – state and outlook 2020”, 2019. 

25  Article 6(1)(f) of Proposal for a Regulation of the European Parliament and the Council 

establishing rules on support for strategic plans to be drawn up by Member States under 
the Common agricultural policy (CAP Strategic Plans) and financed by the European 
Agricultural Guarantee Fund (EAGF) and by the European Agricultural Fund for Rural 
Development (EAFRD), COM/2018/392 final. 

 
 
 
                                                       
18 

23 The agriculture target (3a) of the strategy to 2020 is broken down into distinct 
action areas and has a clear deadline; hence we consider it specific and time-bound. 
However, it presents weaknesses in terms of achievability and relevance and is not 
itself quantified, which limits the scope for measuring how well it is being achieved. 
Instead, the strategy stipulates that the agriculture target must also contribute to 
Targets 1 and 2, which do have target values. Target 1 relates to Natura 2000 areas 
and is measurable. It states that, by 2020, assessments of species and habitats 
protected by EU nature law should show better conservation or a secure or improved 
status for 100 % more habitats and 50 % more species. Target 2 includes the goal of 
“restoring at least 15 % of degraded ecosystems”. It is not clear from the strategy how 
to measure achievement of the 15 % objective or the contribution made to it by 
agriculture. The Commission stated in the mid-term review of the 2020 strategy that 
the restoration target for water bodies had “probably” been achieved (18 % restored), 
but did not give a percentage for any other ecosystems. 

24 In 2005, the Commission began to establish “Streamlined European Biodiversity 
Indicators” (SEBIs), to assess progress towards the EU biodiversity targets. The most 
relevant SEBIs for the agriculture target and/or farmland biodiversity are listed in 
Annex II. The Commission has regularly updated five of these indicators, but eight of 
them go back six years or even longer. For example, the latest available data for 
“livestock genetic diversity” reflects the situation in 2005 and covers just five Member 
States, while the “high nature value area” indicator shows the situation in 2006. These 
data gaps make it impossible to track progress for the SEBIs as a whole. Three regularly 
updated indicators show either an unfavourable trend (farmland birds, grassland 
habitats) or are stabilising (butterflies). The other two cannot be used to monitor 
trends. In the first case (species of European interest), results were distorted by a 
change in methodology, and in the other (nitrogen balance) the most recent data is 
from 2015. 

25 Indicators for monitoring the impact of the CAP on biodiversity are found within 
agri-environment indicators and the common monitoring and evaluation framework 
(CMEF). As an example, the Commission uses “high nature value” (HNV) farming and 
farmland indicators to measure farmland biodiversity in the EU in the scope of the 
2014-2020 CAP (see Annex II). Apart from conserving biodiversity through low-
intensity agriculture, HNV farming seeks to provide societal and environmental 
benefits, such as carbon storage, clean water, wildfire prevention, enhanced genetic 
diversity and protection of cultural values. As shown in Annex II, all three sets of 
indicators include the HNV concept. 

 
 
19 

26 The Commission introduced three HNV-related indicators in the CMEF for 2007-
2013. In the 2014-2020 period, it has kept an HNV farming indicator, which is used to 
show both context and impact. As of 2017, according to a Commission survey, six 
Member States (Czechia, Greece, France, Latvia, Malta and Romania), and a further 
24 EU regions in Belgium, Spain, Italy and Portugal, had neither identified HNV farming 
nor initiated any regular monitoring. The latest rural development progress reports to 
the Commission from Member States and regions (June 2019) confirmed the situation: 
only two thirds of the reports contain quantified information about HNV farmland. 
Certain national and regional authorities, such as Cyprus or Germany, have built up 
their own means of collecting HNV data. HNV indicator values are not comparable 
between Member States, but reflect the Member State’s definition. The Commission 
has not included the HNV indicator in the post-2020 CAP framework. 

27 The impact assessment26 ahead of the Commission’s legislative proposals for the 
2014-2020 CAP acknowledged the importance of incorporating biodiversity concerns 
into the agricultural sector to meet the agriculture target of the biodiversity strategy. 
The Commission states in the assessment that it expected a major contribution to the 
strategy to come from the ‘greening’ component of CAP direct payments (see 
paragraphs 51 to 60). The Commission and Member States mainly address the 
agriculture actions in the EU biodiversity strategy through direct payments (action 8) 
and rural development programmes (action 9) (see Figure 9). 

26  Commission: “Common Agricultural Policy towards 2020”, SEC(2011) 1153. 

 
 
                                                       
Figure 9 – CAP instruments and their link to the EU biodiversity strategy 
to 2020 

20 

Source: ECA. 

No EU strategy for conservation of genetic diversity 

28 Action 10 of the EU biodiversity strategy to 2020 required the Commission to 
encourage the uptake of AECMs for the conservation of genetic diversity and to look 
into developing a related strategy (see Figure 10). 

Figure 10 – Action 10 of the EU biodiversity strategy to 2020 

Source: ECA. 

 
 
 
 
21 

29 The increasing uniformity of food production systems and our limited diet have 
contributed not only to biodiversity decline but also to other unwelcome 
consequences27. Fewer genetic resources mean less natural resilience to pests, 
diseases and severe environmental changes28. 

30 The Commission has continued to support national efforts to reverse the loss of 
genetic diversity through agri-environment climate measures (AECMs) and research 
projects. Member States such as Poland, Denmark and Estonia have developed 
national strategies or programmes on animal or plant genetic diversity. A study from 
2016, contracted by the Commission, recommended that the EU develop a 
comprehensive strategy, in line with its biodiversity strategy, towards the conservation 
and sustainable use of genetic diversity29. The study identified agricultural 
intensification as the major driver for the loss, with its focus on high-yielding breeds 
and new land management patterns (with a strong decline in grazing) leading to 
almost 50 % of all European livestock breeds becoming extinct or assuming 
endangered or critical status. Eight out of nine authorities we surveyed were in favour 
of a strategy for the conservation of genetic diversity. 

The Commission overestimates how much it spends on biodiversity 

31 The Commission tracks annually how much it budgets for biodiversity, but it has 
no target in this regard. It publishes biodiversity financing figures in its reports to the 
CBD and annually in the draft general budget of the EU. In 2019 and 2020, the EU has 
planned to spend around 8 % of its total budget on biodiversity (about €13.5 billion per 
year). The CAP share of this is €10.3 billion per year. The Commission applies 
coefficients of 0 %, 40 % and 100 %, which are adapted from the “Rio markers” from 
the Organisation for Economic Co-operation and Development (OECD). The 
Commission’s criteria for these coefficients are less conservative than the OECD’s (see 
Table 1). 

27  FAO: “The Second Report on the State of the World’s Plant Genetic Resources for Food and 
Agriculture”, 2010; FAO: “The State of the World’s Biodiversity for Food and Agriculture”, 
2019. 

28  EEA: “The European environment – state and outlook 2020”, 2019. 

29  Commission “Preparatory action on EU plant and animal genetic resources”, Final Report, 

2016. 

 
 
                                                       
22 

Table 1 – OECD categories and EU biodiversity coefficients 

OECD

EU

Category

Activities

Biodiversity funding 
coefficient

Criteria used

2

1

0

Expenditure for 
activities for which 
biodiversity is the 
principal (primary) 
objective.

Expenditure for 
activities for which 
biodiversity is a 
significant, but not the 
principal, objective.

Expenditure not 
targeting biodiversity.

100 %

40 %

0 %

The support makes a 
significant contribution 
towards biodiversity 
objectives.

The support makes a 
moderate contribution 
to biodiversity.

The contribution of the 
support is insignificant.

Source: ECA, based on Study on biodiversity financing and tracking biodiversity-related expenditures in 
the EU budget, Commission, 2017; Statement of estimates 2020, Commission, 2019. 

32 Figure 11 shows how the Commission applies these coefficients to CAP spending. 
The Commission does not track and offset expenditure from schemes that could have 
a negative impact on farmland biodiversity. 

Figure 11 – Overview of the method used by the Commission to calculate 
biodiversity funding from the CAP 

Element

EU biodiversity 
coefficient

Planned contribution 
to biodiversity in 2019

Direct 
payments

Greening 
(30 % of direct payments)

Cross-compliance 
(7 % of direct payments)

Remaining 63 % of direct payments

Priority 4 (Restoring, Preserving and 
Enhancing Ecosystems; excluding the 
amounts for areas facing natural 
constraints)

Rural 
development

Focus Area 5E (Carbon conservation 
and sequestration)

Other

Source: ECA, based on Commission data. 

40 %

40 %

0 %

100 %

40  %

0 %

€5.9 bi llion out of 
€43.2 bi llion 
(i .e. ≈ 14 %)

€4.4 bi llion out of 
€14.7 bi llion 
(i .e. ≈ 30 %)

 
 
 
 
 
23 

33 The Commission applies a 100 % coefficient, in line with the OECD approach, to 
rural development expenditure on “Restoring, preserving and enhancing biodiversity” 
(focus area 4A), which specifically targets biodiversity. It also applies a 100 % 
coefficient to expenditure on “Improving water management” (4B) and “Preventing 
soil erosion and improving soil management” (4C). As biodiversity is not the principal 
objective of these two focus areas, they do not meet the criteria for the 100 % 
coefficient. 

34 The Commission applies a coefficient of 40 % to all greening payments even 
though their positive impact on farmland biodiversity cannot be clearly demonstrated 
(see paragraphs 51 to 60). Moreover, greening requirements are generally 
undemanding and largely reflect normal farming practice. We estimated in our special 
report 21/2017: “Greening: a more complex income support scheme, not yet 
environmentally effective” that farmers created the greening elements on only around 
3.5 % of arable land, i.e. no more than 2 % of all EU farmland. Additionally, new 
greening requirements relating to permanent grassland had resulted in a change in 
farming practices on only 1.5 % of EU farmland. 

35 The impact of the cross-compliance element, a sanction system, on farmland 
biodiversity raises some difficulty and is further discussed in paragraphs 41 to 50. To 
account for the contribution made by cross-compliance, the Commission applies a 
40 % coefficient to 10 % of the other direct payment components (around 70 % of 
direct payments; see Figure 14). This is not applied to rural development schemes such 
as funding for areas facing natural or specific constraints, which is not any more 
beneficial to farmland biodiversity than the basic payment scheme. The cross-
compliance coefficients may generally overstate the cross-compliance contribution. 

36 Cyprus, Ireland and Germany did not consider the Commission’s methodology 
accurate. Ireland and Germany, when developing their own biodiversity tracking 
systems, have therefore not used it. They each carried out one tracking exercise, based 
on scientific evidence. In its National Biodiversity Expenditure Review, Ireland used six 
coefficients (0 %, 5 %, 25 %, 50 %, 75 % and 100 %). 

 
 
24 

37 We find that the Commission’s quantification of around €10 billion, resulting 
from the use of only three coefficients (0 %, 40 % and 100 %), is not entirely robust or 
reliable. Our findings are in line with those of independent studies carried out in 
201530 and 201731. 

Most CAP funding has little positive impact on biodiversity 

38 We examined whether, in the 2014-2020 period, direct payments, including 
greening, and cross-compliance, have had a measurable positive impact on 
biodiversity, as required by action 8 of the EU strategy. Action 8 is split into two sub-
actions (see Figure 12). 

Figure 12 – Action 8 of the EU biodiversity strategy to 2020 and its sub-
actions 

Source: ECA. 

30  Medarova-Bergstrom et al.: “Tracking Biodiversity Expenditure in the EU Budget, Final 

Report for the Commission”, 2014. 

31  Ernst&Young: “Study on biodiversity financing and tracking biodiversity-related 

expenditures in the EU budget”, 2017. 

 
 
 
                                                       
25 

Most direct payments do not maintain or enhance farmland biodiversity 

39 At more than €40 billion, direct payments accounted for over 70 % of all EU 
agricultural expenditure in 2019 (see Figure 13). Direct aid schemes include the basic 
payment scheme32, under which farmers activate payment entitlements in proportion 
to the eligible land they declare, the single area payment scheme33, in which payments 
are also made on the eligible area which farmers declare, and the ‘greening’ 
arrangements (see paragraphs 51 to 60). 

Figure 13 – EU agricultural budget – payments (2019) 

Source: EU budget 2019. 

40 According to the Member State authorities we met, the great majority of direct 
payment schemes in the EU have no direct measurable impact on farmland 
biodiversity. According to scientists, voluntary coupled support may have a negative 
impact. This mechanism ties around 10 % of the EU budget for direct payments to the 
production of specific crops or animals (see Figure 14). It thus gives an incentive to 
maintain (or increase) levels of the supported activity34. 

32  See ECA special report 10/2018: “Basic Payment Scheme for farmers – operationally on 
track, but limited impact on simplification, targeting and the convergence of aid levels”. 

33  See ECA special report 16/2012: “The effectiveness of the Single Area Payment Scheme as a 

transitional system for supporting farmers in the new Member States”. 

34  Brady et al.: “Impacts of Direct Payments – Lessons for CAP post-2020 from a quantitative 

analysis”, 2017. 

 
 
 
                                                       
Figure 14 – Direct payments (2018) 

Others

6 %

Redistributive payments

4 %

Voluntary
coupled
support

10 %

27 

42 %

Basic 
Payment
Scheme

Greening

28 %

10 %

Single Area
Payment Scheme

Source: ECA, based on Commission: Annual activity report 2018 – Agriculture and Rural Development, 
June 2019. 

The cross‐compliance sanctions scheme has no clear impact on farmland 
biodiversity 
41 When paying agencies detect that a farmer receiving CAP subsidies does not 
meet basic statutory management requirements (SMRs) and standards of good 
agricultural and environmental condition (GAEC) they should in general reduce the 
payment made to the farmer by between 1 % and 5 %. However, the requirements and 
standards do not apply to all EU farmers, such as those participating in the Small 
Farmers Scheme. SMRs derive from the application of relevant articles of legislation 
(e.g. those relating to Natura 2000, plant protection products and nitrates), and 
therefore replicate existing rules. The legislation on which SMRs are based applies 
independently of the cross‐compliance mechanism. It applies to all farmers in the EU 
whether or not they claim CAP subsidies. Farmers that fail to meet their obligations 
may also be penalised under national law. At times the second penalty may exceed the 
first. 

 
 
 
27 

42 The legislative framework gives Member States a high degree of flexibility to 
define the content of GAEC standards. Member State choices on environmental 
ambition, the definition of farms subject to the GAEC standard, the way farms should 
apply the standard and the way national authorities check compliance thus determine 
a standard’s value for biodiversity. In most cases, paying agencies check between 1 % 
and 2 % of farms subject to a specific GAEC standard, and impose penalties for around 
1 % of those checked. For example, for four out of the five Member States we visited, 
paying agencies identified around 1 million farmers as subject to the conditions of 
GAEC standard 4 (minimum soil cover). They inspected around 16 000 farms and 
applied penalties to 270 subsidy payments. In most cases where they applied 
penalties, they reduced payment by 1 %. 

43 In a previous audit35, we observed significant variations between Member States 
in the application of penalties for infringements. We found that infringement rates for 
several requirements and standards were below 1 %. The SMRs concerned related to 
the conservation of wild birds and natural habitats, while the GAEC standards were 
GAEC 6 on soil organic matter and GAEC 7 on maintaining soil structure and the 
retention of landscape features. All of these have high potential, on paper, to 
contribute to farmland biodiversity (see Figure 15). 

35  ECA special report 26/2016: “Making cross-compliance more effective and achieving 

simplification remains challenging”. 

 
 
                                                       
Figure 15 – The potential of cross-compliance to improve biodiversity 

28 

Source: ECA. 

44 Through action 8b of the EU biodiversity strategy, the Commission committed to 
improving and simplifying the biodiversity-related GAEC standards. It changed the 
structure of cross-compliance in 2015. Certain GAEC standards became part of the 
eligibility rules, and others have changed (see Figure 16). 

 
 
 
Figure 16 – GAEC standards before and after 2015 

29 

Source: ECA, based on Commission information. 

45 The 2013 CAP reform transferred the permanent grassland maintenance 
requirement and the GAEC standard on crop rotation from cross-compliance to 
greening. This meant it applied to fewer farmers. Crop rotation became crop 
diversification (which has less value for biodiversity – see paragraph 54). The 
aggregation of certain standards has not altered their substance: the creation of a new 
standard on soil organic matter did not improve the scheme because the protection of 
soil organic matter was already part of the legal framework when cross-compliance 
began in 2005. 

46 In 2014, the Commission accepted a recommendation we made to include the 
Water Framework Directive in the scope of cross-compliance along these lines in our 
special report 4/2014: “Integration of EU water policy objectives with the CAP: a 
partial success”. The directive is still not part of cross-compliance, although it does 
appear in the Commission’s proposals for the post-2020 CAP. 

 
 
 
30 

47 The SMR component of cross-compliance (see paragraph 41) did not provide 
farmers with an additional obligation to maintain and enhance farmland biodiversity. 
However, inclusion within cross-compliance does provide a regular inspection regime 
for these requirements and does make the farmers aware of the conditions to be 
complied with. 

48 In the cross-compliance framework, GAEC standards 1 and 4-7 have the greatest 
potential in terms of the agriculture biodiversity target (see Figure 15). Only one 
Member State we visited was able to demonstrate a concrete impact, however: the 
German authorities reported that mowing bans under GAEC 4 have benefited breeding 
birds, and that GAEC 5 anti-erosion practices have also promoted biodiversity. GAEC 7 
has protected around two million separate landscape features in Germany, including 
one million hedges and 150 000 wetlands. This is valuable given the long-term decline 
in European hedgerows during the past century (see Box 1). 

Box 1 

Destruction of hedges in the 20th century 

After the second world war, national governments encouraged hedge removal to 
increase food self-sufficiency and allow the use of machinery unable to 
manoeuvre in small fields. The availability of financial incentives resulted in the 
widespread destruction of hedgerows36. For example: 

- 
- 

- 
- 
- 

in France, nearly 70 % of hedges were destroyed between 1945 and 1983; 
in Belgium, up to 75 % of hedges were destroyed in certain regions during 
the 20th century; 
in the Netherlands, the figure was 30 % to 50 % from 1960 to 1994; 
in Italy, up to 90 % of hedges have disappeared in the Po region; 
the Irish regions have removed 15-30 % of their hedges. 

36  Philippe et al.: “Soixante années de remembrement: Essai de bilan critique de 

l’aménagement foncier en France”, 2009; Pointereau et al.: La haie en France et en Europe: 
“Evolution ou régression, au travers des pratiques agricoles”, 2006; Hickie et al.: Irish 
Hedgerows: Networks for Nature, 2004; Bazin et al.: La mise en place de nos bocages en 
Europe et leur déclin, 1994. 

 
 
                                                       
31 

49 The CMEF includes only two output indicators for cross-compliance37: “Number 
of hectares subject to cross-compliance” and “Share of CAP payments subject to cross-
compliance”. According to the EEA, the share of utilised agricultural area covered by 
the various schemes provides an indication of outreach and of the theoretical potential 
to improve biodiversity, but not of effectiveness38. The Commission has no result or 
impact indicators that could measure the specific effects of cross-compliance on 
farmland biodiversity. In our 2016 audit on cross-compliance39, we also concluded that 
the available information did not allow the Commission adequately to assess the 
effectiveness of cross-compliance. 

50 None of the Member States we visited, with the exception of Germany (see 
paragraph 48), provided concrete information about the impact of cross-compliance 
on farmland biodiversity. Studies40 of the effectiveness of action to promote farmland 
biodiversity have not found either positive or negative effects from cross-compliance. 
Some experts have criticised the lack of ambition of the cross-compliance scheme and 
its inadequacy for promoting farmland biodiversity41. 

The potential of greening to improve biodiversity is underdeveloped 

51 Greening comprises three farming practices aimed at benefiting the environment 
and climate (see Figure 17). 

37  Commission: “Technical Handbook on the Monitoring and Evaluation Framework of the 

Common Agricultural Policy 2014-2020”, 2015. 

38  EEA: “The European environment – state and outlook 2020”, 2019. 

39  ECA special report 26/2016: “Making cross-compliance more effective and achieving 

simplification remains challenging”. 

40  Hodge et al.: “The alignment of agricultural and nature conservation policies in the 

European Union”, Conservation Biology, 29(4), 2015; Hauck et al.: “Shades of greening: 
Reviewing the impact of the new EU agricultural policy on ecosystem services”, Change and 
Adaptation in Socio-Ecological Systems, 1, 2014. 

41  Brunk et al.: “Common Agricultural Policy: Cross Compliance and the Effects on 

Biodiversity”, 2009. 

 
 
                                                       
32 

Figure 17 – Greening architecture 

Crop 
diversification

GREENING

Permanent 
grassland

Ecological focus 
areas

Farmers with more than 10  hectares of 
arable land must grow at least two 
crops. Farmers with farms exceeding                       
30 hectares of arable land must 
introduce at least a third crop.

Member States must monitor the 
share of PG in the total agricultural 
area covered by CAP direct payments 
to ensure that it does not fall more 
than 5 % below a reference level. 
Conversion and ploughing of 
environmentally sensitive permanent 
grassland is prohibited.

Farmers with more than 15  hectares of 
arable land must devote an equivalent 
of 5 % of that land to ecological focus 
areas. EU legislation allows farmers to 
meet the obligation with 19 EFA types, 
including land lying fallow, catch crops, 
nitrogen-fixing crops and landscape 
features. 

Source: ECA. 

52 Greening requirements do not apply to holdings in the small farmers’ scheme or 
farms considered ‘green by definition’, such as organic holdings or holdings with over 
75 % of permanent grassland. In 2015, at least one greening obligation applied to 24 % 
of EU agricultural holdings, representing 73 % of all EU farmland42. The aim of greening 
is to provide rewards for crop rotation and the protection of permanent pasture, green 
cover, ecological set-aside and Natura 2000 areas, as required by action 8a of the EU 
biodiversity strategy. The Commission included all of these elements in its 2010 
Communication “The CAP towards 2020”43. However, they were not all part of the 
impact assessment or the 2011 proposal for the 2014-2020 CAP44, which subsequent 
negotiations further watered down (see Figure 18). 

42  ECA special report 21/2017: “Greening: a more complex income support scheme, not yet 

environmentally effective”. 

43  Communication from the Commission: “The CAP towards 2020: Meeting the food, natural 

resources and territorial challenges of the future”, COM(2010) 672 final. 

44  Proposal for a Regulation of the European Parliament and of the Council establishing rules 
for direct payments to farmers under support schemes within the framework of the CAP, 
COM(2011) 625/3 final. 

 
 
 
                                                       
Figure 18 – Greening: from first thoughts to final text 

33 

Source: ECA. 

53 We concluded in our 2017 special report45 that greening had little measurable 
effect: it has led to changes in farming practices on only around 5 % of all EU farmland, 
knowledge of the baseline situation is fragmentary and it is unclear how greening is 
expected to contribute to the EU biodiversity targets. The Commission confirmed in 
201846, citing its own greening evaluation from 201747, that Member States and 
farmers could improve their implementation of greening to deliver better on its 
objectives. Scientific papers have reached similar conclusions48. 

45  ECA special report 21/2017: “Greening: a more complex income support scheme, not yet 

environmentally effective”. 

46  Commission: “Implementation of the CMEF and first results on the performance of the 

CAP”, COM(2018) 790 final, 2018. 

47  Commission: “Evaluation study of the payment for agricultural practices beneficial for the 

climate and the environment”, 2017. 

48  Ekroos et al.: “Weak effects of farming practices corresponding to agricultural greening 
measures on farmland bird diversity in boreal landscapes”, Landscape Ecol 34, 2019, 
pp. 389-402; Pe'er at al.: “Adding Some Green to the Greening”, Conservation Letters, 2017, 
pp. 517-530. 

 
 
 
                                                       
34 

54 Crop diversification rarely leads to a change in land management practices49. A 
Commission Staff Working Document50 has concluded that it is the greening measure 
with the fewest environmental benefits. 

55 The maintenance and protection of permanent grassland is important for 
farmland biodiversity even if the main purpose is the removal of carbon. Studies have 
shown51 that plant diversity levels are much higher where grassland is farmed non-
intensively, e.g. mown only once a year or grazed more sparingly. 

Picture 1 – Non-intensive cattle farming on permanent grassland in 
Ireland 

Source: ECA. 

49  ECA special report 21/2017: “Greening: a more complex income support scheme, not yet 

environmentally effective”, Figure 5. 

50  Commission: Commission Staff Working Document – “Executive Summary of the Evaluation 

of the Regulation (EU) No 1307/2013”, SWD(2018) 479 final. 

51  Plantureux et al.: “Biodiversity in intensive grasslands: Effect of management, improvement 
and challenges”, Agronomy Research 3(2), 2005; Marriott et al.: “Long-term impacts of 
extensification of grassland management on biodiversity and productivity in upland areas. A 
review”, Agronomie, 24(8), 2004. 

 
 
 
                                                       
35 

56 Member States may allow ploughing of permanent grassland, which is 
detrimental to biodiversity. In Poland, farmers can, in principle, convert such grassland 
into arable land, as long as the country’s 5 % overall ceiling is not breached (see 
Figure 17). In Germany and Ireland, farmers need administrative authorisation before 
they can plough, and must reseed an equivalent area with grass, if they are to meet 
the permanent grassland requirement. Although studies indicate that newly seeded 
grassland has lower environmental and biodiversity value52, this is a common practice: 
17 out of 44 farmers with grassland whom we interviewed had ploughed and reseeded 
some of their grassland since 2015. 

57 Farmers are not allowed to plough where land has been designated 
environmentally sensitive to conserve areas of significant biodiversity or maintain the 
benefits of carbon sequestration. In the Member States, this category represents only 
a small part of all permanent grassland, mainly within Natura 2000 areas. In 2016, the 
area of permanent grassland subject to the greening measures was 47.7 million 
hectares, with 7.7 million hectares of environmentally sensitive permanent grassland 
in Natura 2000 areas. The Commission's data from 2018 showed that only four 
Member States/regions (Belgium-Flanders, Czechia, Latvia and Luxembourg) had 
designated environmentally sensitive permanent grassland in non-Natura 2000 areas: 
a total area of less than 0.3 million hectares. 

58 The potential of ecological focus areas to deliver biodiversity benefits depends 
on the types of EFA implemented and how farmers manage them. The options 
preferred by German, Polish and Romanian farmers in the most recent information 
published by the Commission (2017) are mostly those which numerous scientific 
studies have identified53 as being least beneficial for farmland biodiversity, notably the 
sowing of nitrogen-fixing crops and catch crops. The situation in Ireland is anomalous, 
in that over 95 % of farmers are exempted from greening due to the natural 
abundance of grassland. Around 60 % of Cypriot farmers have chosen to meet their 
EFA obligations through the biodiversity-friendly option of fallow land; however, the 
figure for the EU as a whole is less than 20 % (see Figure 19). In 2017, the share of 
arable land in EFAs varied between Member States from 0.2 % to 20 %, and the ratio of 

52  BfN: “Agriculture Report 2017: Biological diversity in agricultural landscapes”, 2017; 

Plantureux et al.: “Biodiversity in intensive grasslands: Effect of management, improvement 
and challenges”, Agronomy Research 3(2), 2005. 

53  Nilsson et al.: “A suboptimal array of options erodes the value of CAP ecological focus 
areas”, Land Use Policy 85, 2019; Ekroos et al.: “Weak effects of farming practices 
corresponding to agricultural greening measures on farmland bird diversity in boreal 
landscapes”, Landscape Ecol 34, 2019. 

 
 
                                                       
arable land to total agricultural area also varies significantly (see examples in 
paragraphs 68 and 69). 

Figure 19 – Various EFAs as a share (%) of arable land, 2017 

36 

The least beneficial for farmland biodiversity

Nitrogen-fixing crops
Catch crops, or green cover

Landscape features
Buffer strips
Other (afforested  areas, agro-forestry, short rotation coppice, 
strips along forest edges, terraces)

Land lying fallow

Source: ECA, based on Commission data. 

59 The CMEF54 includes 22 output and result indicators related to greening. The 
Commission does not have any impact indicators with which to measure the effects of 
greening on farmland biodiversity. 

60 Our survey corroborates the above findings. One third of the authorities that 
responded felt that none of the current greening instruments had improved farmland 
biodiversity. Around half of the authorities stated that the greening requirements need 
to be strengthened in the post-2020 CAP as part of the increased emphasis on 
biodiversity through “enhanced conditionality”. This arrangement, intended to replace 
greening and cross-compliance, should comprise a number of SMRs and 10 GAEC 
standards – three more than in the current CAP. The Commission has also proposed a 
new instrument known as “eco-schemes”. It will be mandatory for Member States to 
design and offer one or more “eco-schemes” covering agricultural practices such as 
enhanced management of permanent pastures and landscapes, nutrient management, 
food and nesting packages for pollinating species, and organic farming. 

54  Commission: “Technical Handbook on the Monitoring and Evaluation Framework of the 

Common Agricultural Policy 2014-2020”, 2015. 

 
 
 
                                                       
37 

Some rural development schemes have potential for improving 
farmland biodiversity 

61 We examined whether the Commission’s and Member States’ rural development 
action, especially their use of agri-environment-climate measures, now focuses more 
on biodiversity conservation, as required by action 9 of the EU strategy (see Figure 6), 
and whether its impact is adequately monitored. Action 9 is split into two sub-actions 
(see Figure 20). 

Figure 20 – Action 9 of the EU biodiversity strategy to 2020 and its sub-
actions 

Source: ECA. 

Agri-environment-climate, Natura 2000 and organic farming measures 
have most potential to maintain or enhance farmland biodiversity 

62 Rural development programmes (RDPs) which Member States and regions 
developed for the 2014-2020 CAP should contain measures to meet the economic, 
environmental and social challenges identified for the geographical area it covers, 
including challenges to biodiversity (see Figure 21). So far, the EU has provided around 
€100 billion in rural development funding for 2014-2020, with a further €61 billion 
coming from Member States. 

 
 
 
Figure 21 – Rural development and biodiversity 

38 

Source: ECA. 

63 The national authorities in the Member States we visited considered that, of the 
measures included in rural development programmes, AECMs, followed by organic 
farming and Natura 2000 measures, offer the greatest potential to contribute to the 
agriculture target of the biodiversity strategy (see Box 2). The available scientific 
research corroborates this view55. 

Box 2 

Rural development measures contributing most to biodiversity 

Farmers signing up for an AECM voluntarily commit for at least five years to 
environmentally friendly farming practices that go beyond the relevant legal 
obligations. 

The organic farming measure provides per hectare support for farmers who 
convert to or maintain organic farming practices and methods. 

The Natura 2000 measure provides annual per hectare compensation payments to 
farmers for the additional costs they incur and the income they forego due to the 
disadvantages resulting from the application of the Birds and Habitats Directives. 

55  See for example CEEweb for Biodiversity: “Rural Development Programmes Performance in 

Central and Eastern Europe: Lessons learnt and policy recommendations”, 2013. 

 
 
 
                                                       
39 

64 The authorities we surveyed confirmed the potential and usefulness of these 
rural development measures for biodiversity conservation, as they contribute to the 
strategy’s agriculture target and allow some progress on the major challenges facing 
biodiversity. 

Less demanding agri-environment-climate measures have higher 
participation rates 

65 “Light green” measures include more farmers across a wider area, make relatively 
modest demands in terms of farming practices, and pay less. “Dark green” measures 
focus on site-specific environmental and biodiversity issues and therefore target fewer 
holdings, require more effort from farmers and pay more for the services provided. 

66 Scientists and NGOs consider that “dark green” schemes deliver greater 
biodiversity than “light green” measures56. However, we found that simple but 
effective lighter green AECMs, such as reducing grazing intensity, limiting the input of 
chemical fertilisers or herbicides and a ban on mowing during nesting periods, do not 
require much time and effort from farmers but also have potential to improve 
biodiversity. We found good examples of both “light green” and “dark green” 
measures with a high potential biodiversity impact in terms of species and habitats in 
all the Member States we audited (see examples from Romania and Cyprus in Box 3). 

56  Lakner et al.: “A CAP-Reform Model to strengthen Nature Conservation – Impacts for Farms 

and for the Public Budget in Germany”, Journal of the Austrian Society of Agricultural 
Economics, December 2018; Goetz et al.: “New Perspectives on Agri-environmental 
Policies: A Multidisciplinary and Transatlantic Approach”, 2009. 

 
 
                                                       
40 

Box 3 

Examples of “light green” and “dark green” agri-environment-climate 
measures 

“Light green” measures 

In Romania, “light green” measures target biodiversity through, for example, non-
intensive or traditional farming practices on grasslands: chemical fertilisers and 
pesticides are prohibited and grazing is limited to a maximum of one livestock unit 
per hectare. In Cyprus, one measure requires specific documentation, bans the 
use of chemical pesticides and fertilisers and demands mechanical weeding on 
designated crops. 

“Dark green” measures 

Romania offers measures protecting designated species of birds and butterflies. 
Cyprus has two measures specifically targeting HNV farming areas. One addresses 
the maintenance and repair of dry stone walls, and the other covers a number of 
environmental practices in HNV areas, such as active soil enrichment for perennial 
crops or a ban on grazing during the main flowering season. 

67 Farmer participation rates were lower for “dark green” than for “light green”
AECMs: we estimate that in Cyprus, Germany (Rhineland-Palatinate) and Romania, no 
more than about 15-20 % of all AECMs are “dark green”. The authorities, backed by 
scientific evidence57, mainly gave the following explanation: 

o

o

In highly intensive and profitable farming areas, full compensation for “dark
green” measures would have to be so high that the Member States would be
unable to fund a sufficient number of other measures and actions.

The current system of calculating compensation payments on the basis of
“income foregone/costs incurred”, especially in non-intensive farming areas,
prevents Member States from paying farmers their real costs where not much
income is foregone; this is because the calculation omits transaction costs,
undervalues the quality of outcomes and is based on averaging the cost to
multiple farmers.

57  Barnes et al.: “Alternative payment approaches for noneconomic farming systems 

delivering environmental public goods”, 2011; Berkhout et al.: “Targeted payments for 
services delivered by farmers”, 2018. 

41 

Arable farmers are less likely to commit to biodiversity-relevant agri-
environment-climate measures 

68 Scientists recognise that intensification of arable systems has led to a decline in 
biodiversity on arable farmland in the EU58. In addition, studies across Europe have 
found that species decline on grasslands is particularly associated with neighbouring 
arable farming practices59. We found that in Ireland and Germany (Rhineland-
Palatinate), biodiversity AECMs on permanent grassland outweigh those on arable land 
by both number of applications and hectares. The same goes for Romania, even 
though arable land represents around two thirds of the country’s agricultural area. In 
Germany (Rhineland-Palatinate – 60 % arable), our sample showed that, where 
farmers do sign up for a measure on arable land, they tend to restrict it to 
unproductive parcels rather than to those that are larger, more productive and more 
intensively farmed. 

69 Over 70 % of Cypriot farmland is arable. In 2018, even though Cyprus offered four 
biodiversity AECMs for arable farmers, these accounted for only 7 % of all AECMs 
entered into that year. Some 85 % of all applications were for permanent crops, such 
as nuts, fruit trees and carob trees. 

Result-based schemes have positive effects but are rare 

70 Only two biodiversity-relevant AECMs we examined in the Member States in our 
sample for the 2014-2020 period were result-based. A low share of result-based 
schemes is also common overall60. Under the other 44 AECMs in our sample of 
Member States, farmers were paid for committing to (or refraining from) certain 
activities but not for the results they achieve. The national and regional authorities we 
met considered that result-based rural development schemes can be more beneficial 

58  Boatman et al.: “The Environmental Impact of Arable Crop Production in the European 

Union: Practical Options for Improvement”, November 1999; Ahnström et al.: “Farmers' 
Interest in Nature and Its Relation to Biodiversity in Arable Fields”, International Journal of 
Ecology, 2013. 

59  Ekroos et al.: “Optimizing agri-environment schemes for biodiversity, ecosystem services or 
both?” Biological Conservation, 172, 2014; Seibold et al.: “Arthropod decline in grasslands 
and forests is associated with drivers at landscape level”, Nature, 2019. 

60  Russi et al.: “Result-based agri-environment measures: Market-based instruments, 

incentives or rewards?” Land Use Policy, 54, 2016; Herzon et al.: “Time to look for evidence: 
Results-based approach to biodiversity conservation on farmland in Europe”, Land Use 
Policy, 71, 2018. 

 
 
                                                       
42 

for biodiversity. They underlined that, although such schemes require more effort to 
design and develop, they can generate better monitoring data. One example is the 
design and use of a scoring system showing how many different plant species can be 
found on a given parcel. Result-based schemes (see examples in Box 4) give farmers 
greater freedom to decide how to manage their land, and therefore more ownership 
of their results61. 

Box 4 

Result-based AECM 

The Burren programme in Ireland focuses on conserving the unique farming 
landscape in a specific area. It has been part of the Irish RDP since 2016. 
Environmentalists head up the scheme, which offers payment both for actions and 
for results. Advisors help farmers to draw up a plan of activities to maintain or 
increase the conservation status of agricultural parcels. Results are assessed 
annually. If they score too low no payment is made. Higher scores result in higher 
payments. The overall biodiversity performance of the areas/parcels under the 
scheme has gradually improved every year since inception. 

Burren landscape in Ireland 
Source: ECA. 

In Germany (Rhineland-Palatinate), the regional authorities set up a specific 
nature protection programme for permanent pasture. This requires participating 
farmers to count and document the plant species on their land. No payment is 
made if the number of plant species on a parcel is below a given threshold. 

61  Ibid. 

 
 
 
                                                       
43 

Few rural development indicators focus on results and many have not 
been updated recently 

71 The CAP rules62 require Member States to assess “to what extent RDP 
interventions [have] supported the restoration, preservation and enhancement of 
biodiversity including in Natura 2000 areas, areas facing natural or other specific 
constraints and HNV farming, and the state of European landscape”. There is just one 
CMEF result/target indicator in place to help them do this: “percentage of agricultural 
land under management contracts supporting biodiversity and/or landscapes”. No 
CMEF impact indicator measures the effect of rural development policy on farmland 
biodiversity. For the post-2020 CAP, the Commission has proposed three result and 
three impact indicators for assessing farmland biodiversity. However, as we stated in a 
recent opinion63, these elements should be presented as part of a coherent framework 
(see Figure 22). 

62  Annex V of Regulation (EU) No 808/2014 laying down rules for the application of Regulation 
(EU) No 1305/2013 on support for rural development by the European Agricultural Fund for 
Rural Development (EAFRD). 

63  ECA opinion 7/2018 concerning Commission proposals for regulations relating to the 

common agricultural policy for the post-2020 period. 

 
 
                                                       
Figure 22 – Farmland biodiversity-related result and impact indicators 
for post-2020 CAP 

44 

Source: ECA, based on COM(2018) 392 final. 

72 Member States are free to develop further indicators with which to measure the 
impact of their RDPs on biodiversity. None of the five Member States we visited has 
developed additional result or impact indicators to demonstrate measurable changes 
in farmland biodiversity. 

 
 
 
45 

73 In addition to the CMEF, in 2006 the Commission developed a set of 28 agri-
environment indicators to track the integration of environmental concerns into the 
CAP64. For certain indicators the most recent Eurostat data is at least ten years old (see 
Figure 23), and for two indicators (“HNV farmland” and “genetic diversity”) the 
Commission has never published any data. 

Figure 23 – Agri-environment indicators not updated since 2010 or 
earlier 

Source: ECA, based on Commission data. 

64  Commission: “Development of agri-environmental indicators for monitoring the integration 

of environmental concerns into the CAP”, COM/2006/0508 final, 2006. 

 
 
 
 
 
                                                       
46 

Conclusions and recommendations 

74 We examined the contribution of the CAP to maintaining and enhancing 
biodiversity and whether the agriculture target (3a) of the EU biodiversity strategy is 
likely to be reached. The target stipulates that there must be a measurable 
improvement in biodiversity. Overall, we found that this was not the case: neither the 
Commission’s evaluation nor our audit revealed any such improvement. In fact, the 
available data on farmland biodiversity in the EU unambiguously shows a decline in 
recent decades. 

75 The agriculture target and actions in the EU biodiversity strategy are not 
measurable, making it difficult to assess performance. The Commission has not 
ensured that the design and implementation of the agricultural part of the biodiversity 
strategy to 2020 was satisfactorily coordinated with international commitments in this 
area. Genetic diversity in farm crops and animals is in continuing decline in the EU 
(paragraphs 20 to 30). 

76 The Commission’s tracking of CAP spending benefiting biodiversity is unreliable 
because of methodological weaknesses: some coefficients were set at higher levels 
than suggested by OECD methodology, and the tracking arrangements include certain 
expenditure types without clear proof that they are beneficial for biodiversity 
(paragraphs 31 to 37). 

 
 
47 

Recommendation 1 – Improve coordination and design for the 
post-2020 EU biodiversity strategy and track expenditure more 
accurately 

The Commission should: 

(a)  work with the Member States to define concrete and measurable actions, to be 

implemented by a given date, for the agriculture chapter of the post-2020 EU 
biodiversity strategy and subsequent related actions; 

(b)  assess how to better coordinate and create synergies between the agriculture 
components of Member States’ biodiversity strategies and the agricultural 
chapter of the post-2020 EU biodiversity strategy, and give genetic diversity a 
prominent place both in the post-2020 EU biodiversity strategy and in subsequent 
actions; 

(c) 

revise its biodiversity budget tracking to align it with new legislative changes, 
supported by scientific evidence, and closely aligned with the approach of the 
OECD. 

Timeframe: 2023 

77 CAP direct payments represent around 70 % of the EU’s agriculture expenditure. 
However, the impact on biodiversity of the requirements associated with direct 
payments, including greening, and cross-compliance, is either negative (for example 
for some voluntary coupled support schemes), limited or unknown. The Commission 
has not improved the value of cross-compliance for promoting biodiversity since 2011, 
and the Water Framework Directive is still not part of the scheme. Certain cross-
compliance standards could make a significant contribution to biodiversity, but neither 
the Commission nor the Member States have measured their impact, and these 
provide weak incentives. There are no standard cross-compliance penalties 
corresponding to biodiversity-relevant SMRs and GAECs, and penalties for detected 
infringements are low (paragraphs 39 to 50). 

78 The Commission designed the greening scheme to meet, among other things, its 
commitment, under the biodiversity strategy, to reward farmers for environmental 
measures that go beyond cross-compliance. However, biodiversity benefits little from 
greening. Crop diversification rarely brings favourable changes in farming practices. 
The benefits of permanent grassland depend on farming practices, which Member 
States do not track. Ecological focus areas can benefit biodiversity, but Member States 

 
 
48 

and farmers typically favour low-impact options such as catch or nitrogen-fixing crops. 
The greening scheme has triggered few changes in farming practices (paragraphs 51 
to 60). 

Recommendation 2 – Enhance the contribution of direct 
payments to farmland biodiversity 

As the Commission committed to enhance CAP direct payments for environmental 
public goods, in particular biodiversity, when assessing Member States’ CAP strategic 
planning for the post-2020 period, the Commission should now ensure that the set of 
all CAP instruments acting together, and including specifically the direct payment 
schemes, the new “enhanced conditionality” and eco-schemes, are more ambitious 
and deliver more for biodiversity than the instruments available in the 2014-2020 
period. 

Timeframe: 2023 

79 The EU’s rural development instruments have greater potential than direct 
payments for maintaining and enhancing biodiversity. The most suitable are agri-
environment climate measures, followed by organic farming and Natura 2000 
payments (paragraphs 62 to 64). 

80 Member States offer farmers various AECM options. “Light green” schemes are 
more common, more accessible and more popular among farmers, but less beneficial 
to biodiversity. Less frequent, and less popular, are “dark green” schemes, which are 
more focused and demanding but deliver greater environmental benefits. Permanent 
grassland schemes are more common, and take-up is higher, than schemes to preserve 
biodiversity on arable land. Action-based schemes are also more common, though less 
effective, than schemes which reward farmers for achieving results (paragraphs 65 
to 70). 

 
 
49 

Recommendation 3 – Increase the contribution of rural 
development to farmland biodiversity 

The Commission should: 

(a)  consider linking the level of co-financing for different measures more closely to 

their assessed biodiversity impact; 

(b)  when approving Member States’ CAP strategic plans, ensure that, wherever 

necessary, they include ambitious biodiversity-friendly rural development 
interventions and commitments addressing the most relevant biodiversity issues 
and needs, and that the Member States make these schemes attractive for both 
arable and grassland farms. 

Timeframe: 2023 

81 We found that there are no reliable indicators for measuring the results and 
impacts of direct payment schemes and rural development programmes in relation to 
biodiversity. The only mandatory CMEF rural development indicator for measuring the 
degree of farmland biodiversity is an output indicator. The few available agri-
environment indicators for tracking the integration of environmental concerns into the 
CAP are not always up-to-date (paragraphs 71 to 73). 

82 The recently published study, contracted by the Commission to support the 
evaluation of the impact of the CAP on habitats, landscapes and biodiversity confirms 
our findings. It concludes that, due to a lack of data, it is not possible to estimate the 
net combined impact on biodiversity of CAP instruments and measures. Overall, 
however, the results of biodiversity monitoring strongly suggest that the CAP has not 
been sufficient to counteract the pressures on biodiversity from agriculture, either in 
semi-natural habitats or on more intensively managed farmland. 

 
 
50 

Recommendation 4 – Show the impact of CAP measures on 
farmland biodiversity  

The Commission should develop reliable farmland biodiversity indicators with which to 
assess the positive and negative impacts of the CAP instruments, allowing it then to 
establish a baseline for the reformed CAP and contribute to developing more effective 
post-2020 CAP payment schemes and instruments, such as “enhanced conditionality”, 
eco-schemes and rural development measures. 

Timeframe: 2022 

This Report was adopted by Chamber I, headed by Mr Nikolaos Milionis, Member of 
the Court of Auditors, in Luxembourg at its meeting of 19 May 2020. 

For the Court of Auditors 

Klaus-Heiner Lehne 
President 

 
 
 
 
 
 
 
 
51 

Annexes 

Annex I – Main audit work at Member State level 

Member States 
covered 

Visits to Member States 

Basis for selection 

Audit work 

Features:  
•  almost 30 % of all 
declared EAFRD 
expenditure; 

•  a wide range of farming 

practices; 

•  different shares of 

agricultural land under 
intensive farming. 

• 

Interviews with authorities 
and NGOs; 

•  Visits to farms, including 

structured interviews with 
21 farmers about agricultural 
practices. 

State of nature and 
farmland biodiversity, 
efforts made to favour 
biodiversity, geographical 
characteristics and farming 
practices. 

•  The response rate for the 
9 questionnaires sent to 
national and regional 
agricultural and 
environmental authorities 
was 100 %; 

•  The questionnaire covered 

the EU biodiversity strategy, 
the CAP, and farmland 
biodiversity monitoring and 
financing. 

Cyprus, Germany, 
Ireland, Poland, 
Romania 

Survey 

National: 
Bulgaria, Denmark, 
Estonia, Italy, 
Portugal 

Regional: 
Flanders (Belgium), 
Wallonia 
(Belgium), 
Campania (Italy), 
and Lombardy 
(Italy) 

2019 Statement of Assurance audit 

Czechia, Germany, 
Denmark, Spain, 
France, Hungary, 
Ireland, Italy, 
Poland, Portugal, 
Sweden, United 
Kingdom 

Source: ECA. 

Statistical sampling. 

Structured interviews on 
agricultural practices with 
57 farmers. 

 
 
 
Annex II – Biodiversity indicators 

SEBI (Streamlined 
European  Biodiversity 
Indicators)

001a Abundance and 
distribution of selected 
European species (Birds)
001b Abundance and 
distribution of selected 
European species (Butterflies)

003 Species of European 
interest

005 Habitats of European 
interest

019 Agriculture: nitrogen 
balance

004 Ecosystem coverage

016 Freshwater quality

020b Area under practices 
potentially supporting 
biodiversity: organic farming
020a Area under practices 
potentially supporting 
biodiversity: HNV

002 Red List Index  for 
European Species

006 Livestock genetic 
diversity

009 Critical load 
exceedance  for nitrogen

025 Financing biodiversity 
management

*
*

*
*

*
*

*
*
*
*
*
*

*
*

*

*
*
*

*
*

*
*

*

Updated regularly

The latest  data on 2014 or earlier

No data available  or data 
concerns 2010 or earlier years
Overlap

AEI (Agri-environment 
indicators)

2. Agricultural areas under 
Natura 2000

4. Area under organic 
farming

5. Mineral fertilizer 
consumption

6. Consumption  of 
pesticides

10.1 Cropping patterns

12. Intensification/ 
extensification

15. Gross nitrogen balance

16. Risk of pollution by 
phosphorus

20. Water abstraction

21. Soil erosion

25. Population trends of 
farmland birds

1. Agri-environmental 
commitments

9. Land use change

14. Risk of land 
abandonment

22. Genetic diversity

23. High Nature Value 
farmland

*
*

*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*

*
*

*
*

*
*

*
*

*
*
*

Situation as of 19 February 2020.

Each *  marks a Directorate-General  of the 
Commission who indicated that the indicator 
is relevant  for biodiversity or Target 3a. In 
total we  asked three  Directorates-General.

Source: ECA, based on Commission data. 

52 

CMEF (Common 
Monitoring  and 
Evaluation Framework)

C. 19 Agricultural area 
under organic farming

C.33 Farming intensity

C. 34 Natura 2000 areas

C.35 & I.08 Farmland Bird 
Index  (FBI)

C.36 Conservation status 
of agricultural habitats 
(grassland)

C.40 & I.11 Water quality

C.41 & I.12 Soil organic 
matter in arable land

R.07 & T.9 Share of agricultural 
land under management 
contract supporting biodiversity 
and/or landscapes
R.12 (PI)  Share of 
grassland in total utilised 
agricultural area

R.14 (PI)   Share of area 
under greening practices

C.21 Livestock units

C.31 Land cover

C.37 & I.09 HNV farming

C.39 & I.10 Water 
abstraction in agriculture

R.11 (PI)  Crop diversity

R.13 (PI)  Share of 
ecological focus  area (EFA) 
in arable land

Note: the graph does not 
include CMEF output 
indicators.

*
*

*
*
*
*
*
*

*
*

*
*

*

*

*
*
*

*
*

*
*

*

*
*

*
*

*

*
*
*

*
*

For C.21, C.39/I.10, R.11 more 
recent  data can be available, 
but not updated in agri-food 
portal yet.

 
 
 
 
 
53 

Terms and abbreviations 

AECM: Agri-environment climate measure. Any one of a set of optional practices going 
beyond the usual environmental requirements and entitling farmers to payment from 
the EU budget. 

CAP: Common agricultural policy. The EU’s single unified policy on agriculture, 
comprising subsidies and a range of other measures to guarantee food security, ensure 
a fair standard of living for the EU’s farmers, promote rural development and protect 
the environment. 

CBD: UN Convention on Biological Diversity. Multilateral treaty on the conservation of 
biodiversity, the sustainable use of its components and the fair and equitable sharing 
of benefits arising from the use of genetic resources. 

CMEF: Common monitoring and evaluation framework. The rules and procedures for 
evaluating the performance of the common agricultural policy. 

DG AGRI: Commission Directorate-General for Agriculture and Rural Development. 

DG ENV: Commission Directorate-General for Environment. 

EEA: European Environment Agency. 

EFA: Ecological focus area. An area of land on which farmers apply agricultural 
practices benefiting the climate and the environment. 

FAO: UN Food and Agriculture Organization. 

FBI: Farmland bird index. An indicator of changes in bird numbers and species on 
farmland over time. 

GAEC: Good agricultural and environmental condition. The state in which farmers must 
keep all agricultural land, especially land not currently used for production, in order to 
receive certain payments under the CAP. Includes issues such as water and soil 
management. 

HNV: High nature value. The characteristic of non-intensive farming which reflects its 
benefits for wildlife and the natural environment. 

IPBES: Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem 
Services. An international body open to all UN countries, which, in response to 
requests from decision-makers, assesses the state of biodiversity and of the ecosystem 
services it provides. 

 
 
54 

JRC: Joint Research Centre. The Commission's science and knowledge service, 
providing scientific advice and support for EU policy. 

OECD: Organisation for Economic Co-operation and Development. 

Permanent grassland: Agricultural land on which grasses or other herbaceous forage 
crops are grown for more than five consecutive years. 

RDP: Rural development programme. A set of national or regional multiannual 
objectives and actions, approved by the Commission, for the implementation of EU 
rural development policy. 

SEBI: Streamlined European Biodiversity Indicators. An EU initiative to develop a single 
comprehensive set of data for assessing and reporting on progress towards the targets 
and commitments of the EU biodiversity strategy to 2020 and other international 
agreements. 

SMR: Statutory management requirement. An EU or national rule on the management 
of farmland to safeguard public, animal and plant health, animal welfare and the 
environment. 

 
 
Replies of the Commission 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=53892 

Timeline 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=53892 

 
 
 
 
 
 
 
 
 
Audit team 

The ECA’s special reports set out the results of its audits of EU policies and 
programmes, or of management-related topics from specific budgetary areas. 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 carried out by Audit Chamber I, which is headed by ECA 
Member Nikolaos Milionis. The audit was led by ECA Member Viorel Ștefan, supported 
by Roxana Banica, Head of Private Office and Olivier Prigent, Private Office Attaché; 
Robert Markus, Principal Manager; Jan Huth, Head of Task; Liia Laanes, Deputy Head of 
Task; Maciej Szymura, Ramona Bortnowschi, Ioan Alexandru Ilie, 
Michail Konstantopoulos and Anna Zalega, Auditors. Marika Meisenzahl provided 
graphical support. Thomas Everett provided linguistic support. 

      
 
 
 
 
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PDF 
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ISBN 978-92-847-4760-3 
ISBN 978-92-847-4731-3 

ISSN 1977-5679 
ISSN 1977-5679 

doi: 10.2865/303309 QJ-AB-20-012-EN-Q 
doi: 10.2865/336742  QJ-AB-20-012-EN-N 

In Europe, the number and variety of animal species on farmland 
– “farmland biodiversity” – is in marked decline. Yet the EU 
committed to stop biodiversity loss by 2020. To do this, The 
Commission planned to allocate €66 billion from the common 
agricultural policy between 2014 and 2020. 

We assessed whether the EU’s agricultural policy has helped to 
maintain and enhance farmland biodiversity. We found that the 
formulation of the agriculture targets in the EU biodiversity 
strategy makes it difficult to measure progress; the way the 
Commission tracks biodiversity expenditure in the EU budget is 
unreliable; the impact of CAP direct payments is limited or 
unknown; and the Commission and Member States have favoured 
lower-impact rural development measures. 

We recommend that the Commission improves the design of its 
next biodiversity strategy, enhances the contribution made to 
biodiversity by direct payments and rural development action, 
tracks biodiversity-related expenditure more accurately and 
develops reliable indicators that are suited to monitoring progress 
in farmland biodiversity. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU.