Using new imaging technologies to monitor the common agricultural policy : steady progress overall, but slower for climate and environment monitoring. Special report No 04, 2020.
Date: 2021-03-20
Institutions: European Court of Auditors
Subjects: EU Member State, EU direct payments, EU financing arrangements, aid to agriculture, audit, climate change policy, environmental monitoring, new technology, remote sensing, report, satellite

EN 

2020 

04 

Special Report  Using new imaging technologies to 
monitor the Common Agricultural 
Policy: steady progress overall, but 
slower for climate and environment 
monitoring 

 
 
 
Contents 

Executive summary 

Introduction 

The Common Agricultural Policy 

Use of satellite images for checking area aid 

Use of Copernicus Sentinel data for monitoring area aid 

Expected benefits of the new monitoring approach 

Audit scope and approach 

Observations 

The Commission has supported the use of new technologies 

The legal framework for checks by monitoring has become clearer 

The Commission has promoted and supported the new approach 

The Commission has been searching for solutions to reduce the number of 
parcels requiring follow-up 

The EU-funded cloud-based services were used for testing rather than for 
operational monitoring 

The results of research projects are yet to be exploited 

Some Member States took action to deploy the new technologies 
for direct payments 

15 paying agencies made selective use of checks by monitoring in 2019 

Paying agencies also use new imaging technologies in their work outside 
checks by monitoring 

Obstacles hampering deployment of the new technologies 

2 

Paragraph 

I-VIII 

01-19 

01-03 

04-10 

11-14 

15-19 

20-22 

23-76 

23-44 

24-30 

31 

32-37 

38-40 

41-44 

45-58 

46-50 

51-54 

55-58 

 
 
 
 
Slower progress in meeting the challenge of using new 
technologies to monitor environmental and climate requirements  59-76 

3 

63-67 

68-72 

73-76 

77-84 

Commission support for the monitoring approach has prioritised direct 
payment schemes 

Paying agencies do not yet use the monitoring approach for cross-
compliance checks and rural development agri-environment climate 
schemes 

The Commission does not require Member States to use new technologies 
to directly monitor the environmental and climate impact of agriculture 
post-2020 

Conclusions and recommendations 

Acronyms and abbreviations 

Glossary 

Replies of the Commission 

Audit team 

Timeline 

 
 
 
4 

Executive summary 

I The Common Agricultural Policy has a long history of using satellite or aerial images 
for checking area-based aid, which nowadays accounts for almost 80 % of the EU 
funding provided to agriculture and rural development. While these images usually 
have very high spatial resolution, before 2017 they were not available with sufficient 
frequency to allow verification of activities taking place on agricultural land throughout 
the year (e.g. harvesting). 

II Since March 2017, the EU-owned Copernicus Sentinel satellites 1 and 2 have been 
providing frequent, freely available, high-resolution images, with the potential to be a 
game changer in Earth observation technology for monitoring agricultural activities. 
Since the images are taken frequently, automated processing of time series data 
throughout the growing season makes it possible to identify, without human 
intervention, crops and monitor certain agricultural practices on individual parcels 
(such as tillage, mowing). Since 2018, paying agencies can use Copernicus Sentinel data 
in place of traditional checks based on field inspections. 

III According to the Commission and CAP stakeholders, Copernicus Sentinel data and 
other technologies for monitoring area aid have significant potential benefits for 
farmers, administrations and the environment. Our audit examined whether the 
Commission effectively encouraged widespread use of these new technologies and 
whether Member States had taken adequate action to deploy them. We looked at the 
Copernicus Sentinel satellite data, images taken by drones, and geotagged images. An 
assessment of the progress made in the use of new imaging technologies is especially 
relevant now, as the results of our audit could be applied in the post-2020 CAP. 

IV We found that both the Commission and some Member States have taken action 
to unlock the potential benefits of the new technologies. The Commission promoted 
the use of new technologies through many conferences and workshops and provided 
bilateral support to many paying agencies. 15 out of 66 paying agencies used the 
Copernicus Sentinel data in 2019 to check aid applications for some schemes and some 
groups of beneficiaries (“checks by monitoring”). Our audit revealed that many paying 
agencies consider that there are obstacles to wider use of the new technologies. 

V Although the Commission has attempted to remove or mitigate some of these 
obstacles, paying agencies expect further guidance from the Commission in order to 
take the right decisions and reduce the risk of future financial corrections. 

 
 
5 

VI Moving to checks by monitoring requires significant changes to IT systems, 
specific resources and expertise. The Commission has taken initiatives to facilitate 
access to Sentinel data and digital cloud processing services, but the take-up by paying 
agencies for operational purposes is still low. 

VII With regard to rural development schemes and cross-compliance, we observed 
limited use of new technologies for both compliance and performance monitoring of 
climate and environmental requirements. We also conclude that the currently 
proposed set of post 2020 CAP performance indicators is largely not designed for 
direct monitoring with Sentinel data.  

VIII We recommend that the Commission provide incentives to Member States to 
use checks by monitoring in the post 2020 CAP as a key control system.  We further 
recommend that the Commission make better use of new technologies for monitoring 
environmental and climate requirements. 

 
 
 
6 

Introduction 

The Common Agricultural Policy 

01 Management of the EU’s Common Agricultural Policy (CAP) involves both the 
Commission and the Member States. Paying agencies in the Member States are 
responsible for administering aid applications, carrying out checks on applicants, 
making payments and monitoring the use of funding. The Commission sets much of 
the framework for spending, checks and monitors the work of paying agencies, and 
remains accountable for the use of EU funds. The CAP has three blocks of support: 

o 

direct payments to provide income support for farmers; 

o  market measures to deal with difficult market situations such as a sudden drop in 

prices; and  

o 

rural development measures with national and regional programmes to address 
the specific needs and challenges facing rural areas. 

02 Figure 1 shows that four-fifths of CAP spending is on area-based schemes under 
direct payments or rural development measures. Paying agencies process payment of 
area-based support to farmers annually, based on the number of hectares farmed and 
on the farmers’ adherence to -specific eligibility rules. 

 
 
Figure 1 – Key CAP support schemes and their expenditure (million euro) 
in 2018 

7 

Source:  ECA based on information from AGREX and the Commission. 

03 The amount farmers receive may be reduced if an inspection detects that they 
have failed to respect rules concerning food safety, animal and plant health, climate 
and environment, protection of water resources, animal welfare and conditions in 
which their farmland is maintained1. These conditional links are known as ‘cross-
compliance’2. 

1  For 2014-2020, rules on cross-compliance requirements are defined in Article 93 and 

Annex II of Regulation (EU) 1306/2013 of the European Parliament and of the Council of 
17 December 2013 on the financing, management and monitoring of the common 
agricultural policy. 

2  For more information on cross-compliance see also our Special report 26/2016: Making 
cross-compliance more effective and achieving simplification remains challenging. 

 
 
                                                      
8 

Use of satellite images for checking area aid 

04 The CAP has a long history of using aerial photographs and satellite images to 
check some of its area-based support. The 1992 CAP reform allowed the use of 
satellite images in place of field inspections (see paragraph 07). The 2003 reform of the 
CAP required Member States to create a computerised geographic information system 
of all agricultural parcels. The 2013 CAP reform made it compulsory to use this Land 
Parcel Identification System (LPIS) together with a Geospatial Aid Application (GSAA), 
introduced progressively from 2015 to enhance checks of aid applications. 

05 The LPIS is based on aerial photographs and satellite images that are corrected 
for geometrical distortion (‘ortho-rectified’). The paying agencies use the LPIS for 
cross-checks on all area-aid applications to verify that they pay only for eligible 
agricultural land and only once for a given area of agricultural land. The LPIS ortho-
images have a very high spatial resolution (mostly 25-50 cm per pixel– see Picture 1), 
and are in general updated every three years. 

Picture 1 – Aerial ortho-photo in an LPIS 

© MAPA – Ministry of Agriculture, Fisheries and Food, Spain. 

 
 
 
9 

06 The LPIS is the cornerstone of the paying agencies’ integrated administrative and 
control systems (IACS) for area-based schemes. While our Special report 25/2016 on 
LPIS identified room for improvement, it also recognised the action taken by the 
Commission and the paying agencies over the years to make it more reliable3. Due to 
the low frequency of updates to LPIS imagery, paying agencies cannot use them to 
verify activities taking place on the parcel during the year (planting, harvesting, 
mowing, etc.). To verify farmers’ declarations and adherence to eligibility rules, paying 
agencies have had to carry out field inspections for a sample of around 5 % of farmers 
(see Picture 2). 

Picture 2 – Field inspection 

Source:   ECA. 

07 Field inspections are time-consuming and costly and provide a one-off record of 
the situation on the field. The Commission developed, since 1992, an alternative 
approach for inspecting agricultural parcels with satellite images from commercial 
providers (such as SPOT, WorldView, PlanetScope) taken at different times throughout 
the year, called ‘checks with remote sensing’ (see Picture 3). According to the 
European Commission’s Joint Research Centre (JRC), across the EU an average of 80 % 
of field inspections are now performed using remote sensing. If the paying agency 
cannot draw a conclusion based on these images an inspector carries out a ‘rapid field 
visit’ to the land parcels concerned. While checks with remote sensing are less costly4, 

3  See also our 2018 annual report, paragraphs 7.16 to 7.18. 

4  DG AGRI and ECORYS, “Analysis of administrative burden arising from the CAP”, 2018, p. 99. 

 
 
                                                      
10 

they still require human intervention in the form of operators, who interpret very high-
resolution (VHR) satellite images, using computer-assisted photo-interpretation. 

Picture 3 – Satellite images used for checks with remote sensing 

Source:  JRC. 

08 The introduction of the GSAA (see paragraph 04) allows farmers to submit aid 
applications and payment claims electronically, together with the geo-location of their 
declared agricultural parcels. Therefore paying agencies’ IT systems now link geospatial 
information to agricultural parcels. 

09 Since June 2015, the EU-owned Sentinel satellites 1 and 2 (see Figure 2), 
launched under the EU’s infrastructure for monitoring the Earth from space, the 
Copernicus programme, have been providing freely available high-resolution images. 
According to the European Space Agency (ESA), the Commission and experts 
consulted, these represent a potential game changer in Earth observation technology 
for CAP monitoring because they: 

o 

offer high spatial resolution, and since March 2017, a high frequency - a new 
image with 10 metres spatial resolution per pixel is available every 5 days, 
compared to 30 metres resolution every 16 days for Landsat, the US satellite 
Earth observation programme; 

 
 
 
11 

o 

o 

produce comparable data over a long time scale, with a high quality of calibration; 
and  

there is a long-term commitment on the part of the Commission to keep 
supplying these images. 

Figure 2 – Copernicus Sentinels 1 and 2 

The Sentinel-1 mission consists of two polar-orbiting radar
satellites (1A and 1B) that send out a microwave signal to 
the Earth and measure the signal that bounces back, 
without  being impaired by the presence of physical clouds. 

The Sentinel-2 mission consists of two polar-orbiting 
satellites (2A and 2B) that measure the visible and infrared 
light reflected from the Earth in 13 different wavelengths. 

© ESA/ATG medialab. 

10 Since Sentinel 1 and 2 images are taken frequently, automated processing of time 
series data throughout the growing season makes it possible to identify crops and 
monitor certain agricultural practices on individual parcels (such as tillage, harvest, 
mowing). Figure 3 shows how the crops can be identified using a time series of 
Sentinel data. This makes it possible to monitor the whole population of aid recipients, 
rather than focusing on checks of a sample of farmers. 

 
 
12 

Figure 3 – Example of a time profile of Sentinel-derived information 
showing changes in the vegetation cover for different crops 

1

0.9

0.8

0.7

0.6

0.5

0.4

0.3

0.2

0.1

X
E
D
N

I

N
O
I
T
A
T
E
G
E
V

0
29-Sep

29-Oct

29-Nov

29-Dec

29-Jan

28-Feb

31-Mar

30-Apr

31-May

30-Jun

31-Jul

31-Aug

Alfalfa [Irrigated (Valladolid)]

Wheat [Rainfed (Valladolid)]

Maize [Irrigated (León)]

Harvest

Mowing

Source:  Instituto Tecnológico Agrario de Castilla y León. 

Use of Copernicus Sentinel data for monitoring area aid 

11 In May 2017, the EU paying agencies signed an informal memorandum, the 
“Malta Declaration”, encouraging the Commission to use new technologies for 
simplification of IACS. In June 2017, the Commission proposed legislative changes 
allowing the Member States to apply a new approach called ‘checks by monitoring’ as 
of 20185. This approach uses automated processes based on the Copernicus Sentinel 
data. The amended rules also allow the use of other new technologies, such as drones 
and geo-tagged photographs or data captured by other satellites, as additional 
evidence for checking compliance under the CAP. 

12 In May 2018, a first paying agency in Italy began to use the new approach for its 
checks in one province (Foggia, Puglia). In 2019, 15 paying agencies (in Belgium, 
Denmark, Italy, Malta and Spain) used checks by monitoring for some of their schemes. 
Figure 4 shows key dates in the introduction of checks by monitoring. 

5  Commission Implementing Regulation (EU) 2018/746 of 18 May 2018 amending 

Implementing Regulation (EU) 809/2014 as regards modification of single applications and 
payment claims and checks. 

 
 
 
 
                                                      
 
Figure 4 – Timeline of key events leading to the introduction of checks by 
monitoring, using Copernicus Sentinel data 

13 

Source:  ECA. 

13 Checks by monitoring combines Copernicus Sentinel 1 and 2 data obtained every 
five days with the information provided by farmers in their applications. Through 
machine learning or other algorithms suitable for processing large quantities of data, 
the paying agencies obtain information on crop types and agricultural activity on all 
the declared parcels/farm holdings for each of the aid schemes. The paying agencies 
then assess the parcels/holdings, using a system of coloured flags assigned to each 
parcel/holding (see Picture 4). 

Picture 4 – Simulation of possible outcome of parcels’ assessment 

Source:  JRC simulation. 

 
 
 
14 

14 Paying agencies assess the activity on the parcels/holdings throughout the year, 
taking into account the latest available Sentinel data and information obtained from 
the farmers. For example, a grassland parcel would be assigned a yellow flag until the 
Sentinel data indicates that it has been mown within the regulatory deadline, after 
which its flag status is changed to green. Due to their spatial resolution, Sentinel data 
are not suited for measuring the area of a parcel. Paying agencies thus measure the 
parcel area in the LPIS, which uses images with higher spatial resolution.Therefore, 
before moving to checks by monitoring, the paying agency’s LPIS needs to be of good 
quality in terms of both the accuracy of eligible area registered and the frequency of its 
update. Figure 5 gives an example of how the checks by monitoring system works. 

 
 
15 

Figure 5 – Simplified example of the application of checks by monitoring 

GEOSPATIAL AID 
APPLICATION 
RECEIVED

SYSTEMATIC TRACKING 
OF CHANGES IN THE 
SATELLITE SIGNAL 
THROUGHOUT THE 
SEASON

ASSESS COMPLIANCE 
WITH ELIGIBILITY 
RULES BASED ON 
CHANGES IN THE 
SATELLITE SIGNAL

• Retrieving  relevant  information 
from previous  campaign  for all 
declared  parcels

• Aggregation  of  declared  parcels 

•

Identification  of parcels  to be 
checked  during  LPIS  update 
(e.g.  permanent  crops)

• Development  of  the vegetation

• Event  detection  (e.g. 

ploughing)

• Land  cover  mapping

• Homogeneity  of  satellite  signal 

within  the  parcel

YELLOW
Indications of potential 
non-compliance  or results
are inconclusive

EXPERT 
JUDGEMENT

FARMER 
INPUT 
REQUESTED

Technical  work  depending 
on non-compliance:

• Review  of  submitted 

evidence

• Visual  interpretation  of 
available  satellite  data

• Rapid  field  visit

Farmer  notified  of the 
potential  non-compliance.  Two 
options:

• Submit  additional  evidence 

(geo-tagged  photos, 
documentation,  etc.)

• Amend  or withdraw 

geospatial  aid  application

ESTIMATE THE 
ECONOMIC IMPACT 
ON THE PAYMENT OF 
NON COMPLIANCE
(at holding  level)

• Less than  €50 per  scheme 

and €250  per holding

5 %

• More  than  €50 per  scheme 
and less than  €250  per 
holding  *

95 %

• More  than  €250  per 

holding

RED
Assessed as non-
compliant. 
Payment deduction 
calculated

GREEN
Assessed as compliant

* 5 % of parcels are sampled for follow up. Remaining 95 % assessed 
as compliant and marked yellow for the following claim year.

Source:  ECA based on procedures at the paying agency of Castile and Leon, Spain. 

 
 
16 

Expected benefits of the new monitoring approach 

15 The Commission, paying agencies, relevant stakeholders and experts agree that 
the monitoring approach using Copernicus Sentinel data represents a major change in 
the management and control of the CAP. 

Increasing compliance, by helping farmers to meet requirements 

16 The traditional system of aid claims and checks is a sequential system, whereas 
checks by monitoring is an interactive system. The checks by monitoring approach can 
take new information into account at any time during the growing season (such as 
newly acquired, more recent Sentinel data, geo-tagged photos, or other documents 
sent by the farmer), and it therefore provides more opportunities for farmers to rectify 
their claims before they are finalised (see Figure 6). Paying agencies can also send 
warning messages to farmers, giving them the opportunity to take corrective action 
(e.g. mowing a field). Therefore, the monitoring approach can prevent non-compliance 
from occurring rather than penalising farmers afterwards. 

 
 
Figure 6 – Traditional checks versus checks by monitoring 

17 

Source:  ECA. 

 
 
18 

Covering all farmers, reducing administrative burden and improving cost-
effectiveness 

17 Under the traditional approach using on-the-spot checks, paying agencies select 
small samples of farmers to check. If a sample field visit takes place, an inspector 
checks the parcel area and the crops grown against the information provided by the 
farmer in the aid claim.  

18 Under the new approach, all agricultural parcels in a region are subject to the 
same monitoring process. Field visits are carried out only if the outcome of the 
monitoring process is inconclusive and  the potential financial impact of non-
compliance exceeds a certain threshold. If this leads to fewer field visits, it reduces the 
burden on the farmer and the costs for the paying agency. According to a recent 
study6, automation, digitalisation, and new technologies for management and controls 
can help mitigate the costs of CAP administration. If the use of satellites means that 
field visits are targeting farms most likely to be non-compliant, this improves their 
efficiency. 

Improving information for farm management  

19 The checks by monitoring approach generates data useful for smart farming 
(using modern technology to increase the quantity and quality of agricultural 
products), which can provide farmers with economic benefits. For example, satellite 
images can provide information about soil nitrogen content or drought stress, which 
could optimise fertiliser application or irrigation, cutting costs for the farmer and 
reducing the negative environmental impacts of the agricultural activity. By providing 
access to their data (LPIS, Sentinel and other satellite images, information on 
environmental requirements), paying agencies thus have the possibility of providing a 
service to their farmers, multiplying the benefits of the new technologies. 

6  DG AGRI and ECORYS, “Analysis of administrative burden arising from the CAP”, 2018, 

pp. 153, 155. 

 
 
                                                      
19 

Audit scope and approach 

20 Our audit examined whether the Commission and Member States have taken 
sufficient steps to unlock the potential benefits of new imaging technologies for CAP 
monitoring. In particular, we assessed whether the Commission effectively encouraged 
widespread use of the new technologies and whether Member States had taken 
adequate action to deploy them. We also sought to identify examples of good practice 
in the use of new technologies for CAP monitoring, as well as shed light on obstacles 
hindering their wider deployment. An assessment of the progress made in the use of 
new imaging technologies is especially relevant now, as the results of our audit could 
be applied in the post-2020 CAP. The increased use of new technologies for CAP 
monitoring may affect the future audit approach taken by national and EU audit 
bodies. 

21 The new imaging technologies included in the scope of our audit are the 
Copernicus Sentinel satellite data, images taken by drones, and geotagged images. Our 
audit did not cover the use of Copernicus Sentinel data for smart farming applications, 
crop yield forecasts or areas outside the CAP. 

22 We obtained our evidence from: 

o 

o 

o 

o 

o 

documentary reviews and interviews with staff at four Commission Directorates-
General (Agriculture and Rural Development; Internal Market, Industry, 
Entrepreneurship and SMEs; Joint Research Centre and Environment), the 
European Environment Agency (EEA) and the Research Executive Agency; 

visits to four paying agencies implementing checks by monitoring in 2019 located 
in Belgium, Denmark, Italy and Spain; 

a survey of 66 paying agencies managing area-related measures in 27 Member 
States (we excluded the United Kingdom as it had entered the Article 50 process 
to leave the EU). The survey asked questions on the use of new imaging 
technologies, progress towards implementing checks by monitoring, and 
challenges identified in preparing for the post-2020 CAP. We received responses 
from 59 paying agencies (an 89 % response rate); 

a visit to the European Space Agency and an expert panel meeting involving 
representatives of the paying agencies, research, industry and of the EEA; and 

analysing the Member States’ results of the cross-compliance inspections for the 
years 2015-2017. 

 
 
20 

Observations 

The Commission has supported the use of new technologies 

23 The Commission has assessed the new imaging technologies as offering 
significant benefits in terms of improving CAP monitoring efficiency (see paragraphs 15 
to 19). We examined whether the Commission has taken sufficient steps to realise 
these benefits by: 

o 

o 

o 

o 

o 

introducing changes to legislation and guidelines to allow the use of new 
technologies to check aid applications; 

providing timely support to paying agencies and promoting the use of new 
technologies; 

identifying examples of good practice and solutions for challenges faced by the 
paying agencies; 

facilitating access for the paying agencies to the Copernicus Sentinel data; and 

initialising and funding research projects, which have the potential to increase the 
use of new technologies for CAP monitoring. 

The legal framework for checks by monitoring has become clearer 

24 According to the results of our survey, around two-fifths of the paying agencies 
consider that the initial legislation adopted in May 2018 (see paragraph 11) did not 
allow pragmatic solutions to implement checks by monitoring. The Commission 
realised that there was a need for further clarification and amended the legal 
framework applicable to the 2019 claim year7. 

25 Our survey shows that for 52 out of 59 paying agencies, one important obstacle is 
uncertainty about the Commission’s conformity clearance procedure in the context 
of the new approach. While, in the case of traditional checks, detailed rules exist on 

7  Commission Implementing Regulation (EU) 2019/1804 of 28 October 2019 amending 

Implementing Regulation (EU) 809/2014 as regards amendments of aid applications or 
payment claims, checks in the integrated administration and control system and the control 
system in relation to cross compliance. 

 
 
                                                      
21 

how to carry out on the spot or remote sensing checks, there are no such rules for 
checks by monitoring. Paying agencies are thus concerned that the Commission may 
later question their approach and the decisions taken, and apply financial corrections. 

26 The Commission understood this concern and took steps to clarify how checks by 
monitoring will be audited in the future through: 

o 

o 

o 

assessing each notification of checks by monitoring against a set of legal and 
technical elements8; 

communicating the results of these assessments to the paying agencies; and 

sending a letter to all paying agencies implementing checks by monitoring in 
2019, expressing its readiness to hold discussions and find a solution if major 
issues arise. 

27 Some of the paying agencies we visited during our audit expected the 
Commission to approve their methodology for checks by monitoring. While the paying 
agencies have discussed a number of technical aspects with JRC experts, the 
Commission has not approved methodologies and does not plan to do so. 

28 In its technical guidelines9, the Commission describes some basic rules for 
checking whether the system correctly interpreted the Sentinel data, by comparing it 
with the situation found on the field. To evaluate the reliability of the automated 
system for assessing the parcels, the Commission has set two initial thresholds for 
paying agencies’ systems not to exceed: 

o 

o 

5 % of false red errors, which occurs when a farmer with a correct declaration is 
assessed as non-compliant. This error has little impact on the EU budget as the 
farmer would most likely appeal; and 

10-20 % of false green errors, which occurs when a farmer who is fully or partially 
non-compliant is paid without this non-compliance being detected by the system. 
This type of error may result in an overpayment, thus having a clear impact on the 

8  Stipulated in Articles 40a and 40b of Regulation 809/2014 and in the JRC ‘Technical 

guidance on the decision to go for substitution of OTSC by monitoring’; 2018; pp. 3 to 8. 

9   JRC; ‘Second discussion document on the introduction of monitoring in place of on the spot 

checks: rules for processing applications in 2018-2019’; 2018, p. 16. 

 
                                                      
22 

EU budget. As systems improve, the Commission expects that it can lower this 
threshold. 

29 The technical guidelines do not provide information on some key elements of the 
quality control arrangements (minimum number of samples for testing, selection 
criteria, reporting requirements). A robust quality assessment framework could 
provide valuable information for the paying agencies implementing the checks by 
monitoring system, while reducing the risk of financial corrections. In 2010, the 
Commission established such a quality assessment framework for LPIS, requiring 
Member States to annually test its quality and take remedial action where required. 
While we identified weaknesses in the LPIS quality framework in our Special Report 
No 25/201610, we also acknowledged its contribution to improving the quality of the 
LPIS. 

30 An issue, which the Commission’s legislative changes have not resolved 
completely, is the complexity of some area aid schemes’ requirements. These are a 
combination of EU and national rules and designed at a time when Copernicus and 
other technologies were not available. They can be very complex for some CAP aid 
measures, such as greening, which involve making direct payments to farmers who 
adopt or maintain farming practices that help in meeting environmental and climate 
goals. These cannot always be monitored remotely, meaning that paying agencies 
continue to need traditional field inspections (see Table 1). The introduction of the 
post-2020 CAP represents an opportunity to reassess the benefits and need for some 
of these requirements. 

10  ECA, Special report 25/2016: The Land Parcel Identification System: a useful tool to 
determine the eligibility of agricultural land – but its management could be further 
improved, paragraphs 65-72. 

 
 
                                                      
23 

Table 1 – Examples of greening requirements and whether they can be 
monitored remotely with Sentinel data 

Can be monitored 

Cannot be monitored 

Presence of a catch crop 

Presence of a nitrogen-fixing crop 

Fallow land  

Presence of two species of plants in the 
catch crop 

Landscape elements (rows of trees, 
hedges, ponds, canals) less than 20m 
wide 

Source:  ECA based on Commission documents and discussions. 

The Commission has promoted and supported the new approach 

31 Our survey indicates that two thirds of the paying agencies consider the 
Commission has provided sufficient support for them to implement the checks by 
monitoring approach. While one fifth of paying agencies did not consider the 
Commission’s support to be adequate, they did not provide valid justification for this 
statement. The remaining respondents were neutral. We found the Commission to be 
active in promoting and supporting checks by monitoring in various ways: 

o 

o 

o 

since May 2017, it has organised more than 15 conferences, workshops, expert 
group meetings and seminars where checks by monitoring was explicitly on the 
agenda; 

from January 2018 to August 2019, it has held bilateral meetings with paying 
agencies interested in implementing checks by monitoring in 15 Member States; 
and 

it has replied to questions from Member States, and made available a single 
Questions & Answers document on the new monitoring approach. 

 
 
 
 
 
24 

The Commission has been searching for solutions to reduce the number 
of parcels requiring follow-up  

32 Nearly nine-tenths of the paying agencies who replied to our survey considered 
the risk of having too many yellow-flagged parcels to be an important or a very 
important drawback. If the fully automated part of the system generates a large 
number of inconclusive parcels from the entire group of claimants, the paying agency’s 
workload may be higher than if it used traditional on-the-spot checks for a small 
sample of claimants. Yellow-flagged parcels under checks by monitoring may need to 
be followed up (after considering the financial impact thresholds described in 
paragraph 35) by: 

(1)  visually checking the available images for that parcel; 

(2)  requesting and checking additional information from the farmer; 

and where these do not allow conclusions to be drawn: 

(3) 

inspecting the field. 

33 Small parcels are frequently assigned yellow flags, mainly due to insufficient 
Sentinel spatial resolution (insufficient number of pixels falling entirely within the 
parcel boundaries). Paying agencies have different definitions of small parcels, from 
0.2 ha to 1 ha. They can be high in number, and cause a lot of work for the paying 
agency, even if they usually represent only a small part of the overall agricultural area 
covered by the paying agency. Table 2 shows the proportion of yellow flagged small 
parcels out of all parcels for three paying agencies we visited. 

Table 2 – Proportion of yellow flagged small parcels (<0.5 ha) out of all 
parcels for three paying agencies using checks by monitoring 

Paying agency 

Belgium (Flanders)  

Denmark 

Spain (Castile and Leon) 

Proportion of small 
parcels in terms of 
number 

Proportion of small 
parcels in terms of area 

1.9 % 

5.7 % 

1.0 % 

0.2 % 

0.3 % 

0.1 % 

Source:  Paying agencies in Belgium (Flanders), Denmark and Spain (Castile and Leon). 

 
 
25 

34 The Commission has proposed the following ways of dealing with small parcels: 

o 

o 

o 

Aggregating adjacent small agricultural parcels of the same holding with the same 
declared land use into a single ‘feature of interest’. The paying agency in Castile 
and Leon (Spain) uses this approach. 

Following up small inconclusive parcels when updating the LPIS, rather than by 
making a site visit. The Commission allows this option only when aerial photos are 
taken annually for the whole country. Denmark has used this option. 

Acquiring very high-resolution satellite data to provide better information on 
small parcels, to remove the need for a field visit. The JRC has recently concluded 
a contract with a provider of such data to test this approach for 2019. Under this 
contract, the paying agencies implementing the checks by monitoring in 2019 can 
obtain time series for small parcels, derived from high-resolution satellite images 
(4m pixel size). Nevertheless, the data will be available too late to be used 
effectively by the paying agencies in the follow-up procedure in 2019. 

 
26 

35 These options help to reduce the number of yellow-flagged parcels. For those 
that remain, the Commission has defined monetary thresholds in its technical 
guidelines11 and Questions & Answers document, with corresponding follow-up 
actions. 

o 

o 

o 

If the impact on beneficiary payment of all the yellow-flagged parcels is expected 
to be low (below €50 at scheme level) then no follow-up is required. 

If the impact is expected to be medium (above €50 at scheme level and below 
€250 at beneficiary level), then a 5 % sample of the yellow-flagged parcels should 
be followed up. 

If the impact is expected to be high (above €250 at beneficiary level), then follow-
up of all such beneficiaries is required. 

36 Lower thresholds imply a higher level of assurance, but also lead to more follow-
up checks and thus higher cost of controls. While the Commission carried out an 
analysis of monetary thresholds in existing CAP legislation and consulted data about 
field visit costs to define the €250 threshold, it did not do so for the €50 threshold. 

37 Some agricultural activities are difficult to monitor with Sentinel satellites, such 
as extensive grazing on grassland, or crop cultivation in greenhouses, as is the absence 
of agricultural activity (e.g. land abandonment). In some Member States, this can also 
lead to large numbers of yellow-flagged parcels. As possible solutions to detect some 
of these activities, the Commission allowed the use of geo-tagged photos as additional 
evidence. The European GNSS Agency has been working during 2019 on the 
development of a smartphone application for geo-tagged photos. Paying agencies in 
Denmark and Italy cooperate with private companies to develop dedicated 
applications. However, the paying agencies we visited did not yet use geo-tagged 
photos in the 2019 claim year (only for pilot testing in Italy). 

11  JRC, Second discussion document on the introduction of monitoring in place of on the spot 

checks: rules for processing applications in 2018-2019, 2018, p. 18. 

 
 
                                                      
27 

The EU-funded cloud-based services were used for testing rather than 
for operational monitoring 

38 Copernicus is the largest space data provider in the world, currently producing 
12 terabytes per day. To facilitate and standardise access to this data, the European 
Commission has been funding the deployment of five digital cloud-based platforms 
providing centralised access to Copernicus data and information, as well as to 
processing tools. These platforms are known as the Data and Information Access 
Services (DIAS). Four of them offer services relevant to agriculture in 201912. They 
must meet various technical requirements and provide the Copernicus data free of 
charge, but they can charge for extra services (such as data processing, data storage, 
and combining Copernicus data with other datasets)13. 

39 The DIAS providers’ services became available during 2018. In autumn 2018, the 
Commission decided to support the paying agencies implementing the checks by 
monitoring approach by subsidising their individual access to one of the four DIAS 
platforms for 2019. The subsidy amounted to €120 000 per DIAS provider to cover 
three phases: technical readiness review of DIAS providers by the Commission, 
onboarding of paying agencies on one of the DIAS provider and operational use of the 
DIAS by the paying agencies in 2019. Although all the paying agencies we visited had 
found it useful to test for free a DIAS platform, most of them used their existing 
infrastructure or contracts as primary processing solutions for checks by monitoring in 
2019. Consequently, the value added by the Commission’s expenditure of €480 000 is 
yet to be established. 

40 According to our June 2019 survey, most paying agencies do not intend to move 
to a DIAS platform soon. Our discussions with the paying agencies and expert panel 
between April and September 2019 highlighted the following uncertainties, delaying 
the move to DIAS providers. 

o 

The cost of DIAS services now and in the future. Due to the technicalities and the 
pay-per-use business models, most paying agencies do not know how much it 
would cost them to run checks by monitoring on DIAS platforms in their country 
or region. 

12   CREODIAS, MUNDI, ONDA and SOBLOO.  

13   The Court has started an audit on the Commission’s efforts to promote the uptake of 

services provided by the EU’s main space programmes COPERNICUS and GALILEO. This 
audit also covers the DIAS. 

 
                                                      
28 

o  Having four DIAS providers available, each with a different technology and 
structure, complicates decision-making by the paying agencies. While the 
Commission claims to have a solution for transferability of data from one DIAS 
platform to another, the paying agencies are not yet aware of it. This is 
complicated further by the uncertainty around the service continuity of some or 
all of the DIAS providers after the end of their contracts. 

The results of research projects are yet to be exploited 

41 Under its Horizon 2020 Research and Innovation programme the Commission has 
granted some €94 million to a range of research projects aiming to monitor agriculture 
using Copernicus Sentinel data14. Among these projects, we identified three which 
contributed directly to ongoing developments in CAP monitoring15. In addition, a key 
project that started in June 2019 is ‘New IACS Vision in Action’ (NIVA), for which EU 
funding is expected to amount almost to €10 million. It aims to modernise the 
integrated administration and control system used by paying agencies, by making 
efficient use of digital solutions and e-tools to reduce administrative burden and 
improve environmental performance. 

42 The ESA funded a project, exploring how the Copernicus Sentinels could be 
utilised to modernise and simplify the CAP. In July 2017, a consortium of five 
companies working together with paying agencies in six Member States16 started the 
project called Sen4CAP. The aim of this project is to provide algorithms, products, 
workflows and examples of good practice for generating satellite-derived markers and 
information relevant to CAP monitoring. 

43 A preliminary version of the Sen4CAP processing system (see Figure 7) became 
available in May 2019 and a final version is planned for early 2020. Paying agencies can 
thus use the Sen4CAP products as a basis for developing their own systems for checks 
by monitoring, but they will need to customise the algorithms to local circumstances. 
For example, while the Sen4CAP markers for harvest work well in northern European 

14  The amount refers to the total EU contribution planned for 34 research projects. European 

Commission CORDIS database, consulted in February 2019. 

15  RECAP (2016-2018), SensAgri (2016-2019) and EO4AGRI (2018-2020) for a total EU 

contribution of €6.7 million. 

16  Czechia, Italy (5 regions), Lithuania, Netherlands, Romania and Spain (Castile and Leon). 
Since April 2019, France has been involved in the project (1 region, 1 department). 

 
 
                                                      
countries, they need to be adapted to the specific situation in southern European 
countries, where the natural drying of crops could be mistaken for harvest. 

Figure 7 – The SEN4CAP process flow 

29 

© Sen4CAP, adapted by ECA. 

44 As most of the research projects are ongoing, the paying agencies implementing 
the monitoring approach in 2019 could only partly benefit from their results. 

Some Member States took action to deploy the new 
technologies for direct payments  

45 We expected Member States to take adequate steps for deploying new imaging 
technologies for CAP monitoring. Consequently, we have reviewed whether the paying 
agencies: 

o 

o 

o 

o 

implemented checks by monitoring in the 2019 claim year; 

used the Copernicus Sentinel data systematically to check some of the aid 
requirements; 

used geo-tagged photos or drones; 

participated in EU or ESA-funded research projects concerning the use of the new 
technologies; and 

o 

carried out pilot projects to test the use of the new technologies. 

 
 
30 

15 paying agencies made selective use of checks by monitoring in 2019 
46 As shown in Figure 8, for the 2019 claim year 15 out of 66 paying agencies in five 
Member States have implemented checks by monitoring on all or part of the area for 
which they are responsible, for all or some aid schemes. Figure 8 also shows seven 
Member States participating in Sen4CAP project. 

Figure 8 – Use of checks by monitoring and participation in the Sen4CAP 
project in 2019 

Source:  ECA based on information obtained from the Commission and visited Member States. 

 
 
 
31 

47 Taking into account the technical guidelines drafted by the JRC, these 15 paying 
agencies have developed diverse methodologies for monitoring the different aid 
scheme requirements applicable in their regions (see Figure 9 and Box 1). Crop types, 
agricultural practices and agro-climatic conditions are important factors that come into 
play. 

Figure 9 – Variety of approaches to checks by monitoring 

Source:  ECA based on information received during visits to Member States. 

 
 
32 

Box 1 

Examples of methodologies and use of Sentinel data for checks by 
monitoring in 2019 

In Belgium (Flanders), the paying agency monitors the eligibility requirements for 
three schemes. For those schemes, farmers have to show use of their land for 
some form of agricultural activity. 

An artificial intelligence algorithm, trained using a time series of Sentinel 1 and 
2 images (in combination with the information contained in the farmers’ 
declarations), predicts the probability that each parcel belongs to one of five 
classes (arable land, grassland, leguminous crops, fallow and non-eligible). Parcels 
where the outcome of the algorithm does not match the farmer’s declaration are 
flagged red and followed up with a field visit. Where the outcome of the algorithm 
is inconclusive (yellow flag), parcels are followed up on screen and, if necessary, 
with a field visit. In 2019, permanent crops are excluded from this process, as they 
are verified using an update of the LPIS. 

In Spain (Castile and Leon), the paying agency monitors the requirements for nine 
schemes. For the basic schemes, it is sufficient to check whether the use of land is 
as arable land, as grassland or for permanent crops. More precise crop 
identification is required for greening and voluntary coupled support (VCS). 

The paying agency thus performs a classification (26 crop classes and 9 non-crop 
classes) using a machine-learning algorithm trained with the farmers’ declarations 
for crop classes and using other data sources to identify non-crop classes. The 
classification is performed with time series of Sentinel 2 images (in combination 
with climate data, and information on elevation, aspect and slope). Other types of 
markers have been developed also, e.g. related to crop type, or to detect certain 
events (for example, the preparation of land for growing crops). All inconclusive 
parcels or parcels with possible non-compliance are flagged yellow. Parcels above 
a certain financial threshold are followed up in the office (see Figure 5) and if still 
inconclusive, then with a field visit. 

48 Although radar data from Sentinel-1 are not impaired by the presence of cloud 
cover, they are used less often by paying agencies because they are more difficult to 
process and interpret. However, some paying agencies (Belgium-Flanders and 
Denmark) have integrated them successfully in their machine learning algorithms while 
others use them for detecting grassland mowing (Italy). 

 
 
33 

49 Table 3 shows for the key area aid scheme (Basic payment scheme), the four 
paying agencies we visited ended up with different proportions of yellow and red 
parcels for possible further follow-up. The variations between the proportions of 
red/yellow flagged parcels are mainly due to the size of parcels farmed, type of the 
parcels/activities monitored (mowing activity is easier to detect than grazing) and the 
methodologies applied (e.g. the number and accuracy of markers). Nevertheless, the 
maximum proportion of parcels requiring field inspection for these paying agencies is 
1 %. 

Table 3 – Summary of first results of the 2019 checks by monitoring for 
BPS (as provided by paying agencies by 07/01/ 2020) 

Country 
(Region) 

Total area 
of parcels 
monitored 
(ha) 

Total 
number of 
parcels 
monitored 

Parcels 
flagged 
red/ yellow 
following 
automated 
processing 

Red/ 
yellow 
flagged 
parcels 
followed
-up in 
the 
office 

Red/ 
yellow 
flagged 
parcels 
inspected 
in the 
field 

Belgium 
(Flanders) 

599 545 

397 568 

3.5 % 

1.5 % 

1.0 % 

Denmark 

2 537 188 

506 717 

11.2 % 

11.1 % 

0.1 % 

Italy (6 
monitored 
provinces) 

Spain (Castile 
and Leon) 

1 104 491 

718 692 

3.3 % 

1.0 % 

unknown 

329 029 

128 479 

2.9 % 

1.9 % 

0.2 % 

Source:  Paying agencies in Belgium (Flanders), Denmark, Italy (AGEA) and Spain (Castile and Leon) 

50 Our survey shows that, in 2020, a further 13 paying agencies in eight Member 
States intend to start checks by monitoring. This would mean that in 2020, 28 paying 
agencies in 13 Member States might be applying checks by monitoring approach for 
some aid schemes and for part of the area for which they are responsible (see 
Figure 10). In order to be ready for implementation in 2020, 11 of those 13 paying 
agencies have invested in IT infrastructure and carried out pilot projects. Eight have 
also improved the quality of their LPIS and made changes to organisational processes. 
Six of them have already had consultations with farmers' associations. 

 
34 

Figure 10 – Intended use of checks by monitoring by 28 paying agencies 
in 2020, by scheme and scope of application 

Source:  ECA survey. 

Paying agencies also use new imaging technologies in their work outside 
checks by monitoring 

51 Many paying agencies, even those that do not use checks by monitoring, are 
using new imaging technologies for other aspects of their work (see Figure 11). 

 
 
 
Figure 11 – Paying agencies’ uses of imaging technologies for compliance 
checks on CAP area subsidies by June 2019 

35 

Source:  ECA survey. 

52 Ad-hoc use of Sentinel images for visual checks and geo-tagged photos are the 
most widespread. Almost half of the paying agencies use geo-tagged photos, usually 
taken by their inspectors rather than by farmers. 

53 In addition to the 15 paying agencies, which implemented checks by monitoring 
in 2019, 12 paying agencies replied that they use the Copernicus Sentinel data or other 
satellite data for checks on aid applications. Some paying agencies have also been 
involved in key research projects such as Sen4CAP (see paragraph 42), Sentinels 
Synergy for Agriculture (SensAgri), Reinforcing CAP (RECAP) or Earth Observation for 
Agriculture (EO4AGRI). 

54 Our survey results showed that eight out of 59 paying agencies had used drones. 
In Denmark, the paying agency’s inspectors use drones to check areas that are difficult 
to access, reducing the health and safety risk to them, as well as the time needed for 
checks. Paying agencies most often mention limited autonomy and regulatory 
restrictions as reasons for not making greater use of drones. 

Obstacles hampering deployment of the new technologies 

55 Our survey identified a number of obstacles, which delay the implementation of 
checks by monitoring by paying agencies (see Figure 12). 

 
 
36 

Figure 12 – Obstacles preventing paying agencies from applying checks 
by monitoring 

Source:  ECA survey. 

56 While Commission action can remove or mitigate some of these obstacles (see 
paragraphs 29 and 34 to 40), others need to be tackled by the paying agencies. These 
include developing IT infrastructure, adapting internal processes and changing 
organisational structure to support effective use of checks by monitoring. 

57 Our discussions with paying agencies and experts highlighted three key 
challenges: 

o 

o 

investing in the new monitoring approach while faced with uncertainty about the 
post-2020 CAP17 (for which the Commission proposed a new delivery model and a 
new area monitoring system to be set up by the Member States); 

developing innovative IT solutions, such as the processing of time series of 
Sentinel data (high volume of data) and machine-learning algorithms (rather than 

17   Proposal for a Regulation of the European Parliament and of the Council on the financing, 
management and monitoring of the common agricultural policy and repealing Regulation 
(EU) 1306/2013. SWD(2018) 01 final. 

 
 
 
                                                      
37 

standard image-processing tools) where some paying agencies lack relevant 
expertise; and 

o 

achieving potential synergies between agencies by working together (either 
across the EU or in voluntary groups). This could be valid for the pre-processing of 
Copernicus Sentinel data, archiving, or for the provision of very high-resolution 
images for the follow-up of small parcels (see paragraph 34). 

58 Despite the challenges, Figure 13 shows that most paying agencies plan to use 
new technologies in their post-2020 CAP systems for checking aid applications, 
although the types and expected uses of technology differ. 

Figure 13 – Processes the paying agencies expect to use in future to 
check aid applications in the post-2020 CAP 

Source:  ECA survey. 

 
 
38 

Slower progress in meeting the challenge of using new 
technologies to monitor environmental and climate 
requirements 

59 In addition to using new technologies to carry out eligibility checks for direct 
payment area aid, we expected both the Commission and Member States to take 
initiatives in using these technologies for monitoring certain environmental and 
climate requirements, such as the obligation to grow a catch crop or the ban on 
stubble burning. 

60 This technology will become more important in the post-2020 CAP, since the 
Commission's legislative proposals introduce a mandatory area monitoring system for 
the purposes of monitoring agri-environment-climate policy.  

61 We examined whether the Commission had taken appropriate steps towards 
using new imaging technologies for cross-compliance and rural development agri-
environment-climate requirements through: 

o 

o 

o 

o 

proposing changes to legislation; 

assessing to what extent current requirements can be monitored by new 
technologies; 

identifying, sharing and supporting examples of good practice; and 

assessing how the new technologies can help in monitoring climate and 
environmental requirements. 

62 We also reviewed whether paying agencies had started using the new 
technologies to monitor cross-compliance or agri-environment-climate schemes, or 
whether they intended to do so in the near future. 

 
 
39 

Commission support for the monitoring approach has prioritised direct 
payment schemes 

63 The cross-compliance rules (see paragraph 03) comprise standards for Good 
Agricultural and Environmental Condition (GAEC) of land, established nationally, and 
Statutory Management Requirements (SMRs) set at EU level18. There are seven GAEC 
standards and three area-related SMRs covering environment, climate change, and the 
good agricultural condition of land. 

64 Agri-environment payment schemes are diverse across the EU. They aim at 
enhancing the agriculture-environment-climate relationship by encouraging farmers to 
undertake environmentally friendly practices. Farmer participation in these measures 
is voluntary. 

65 To date, the Commission’s work has prioritised the use of checks by monitoring 
for area-based direct payment schemes, rather than for cross-compliance and rural 
development agri-environment-climate schemes. The legal framework for applying 
checks by monitoring to direct payments and rural development has been available 
since May 2018 (see paragraph 11), and in the course of 201919 the Commission 
prepared a legal framework for applying the checks by monitoring approach to cross-
compliance (see paragraph 24).  

66 In 2019, the Commission started a review of the cross-compliance requirements 
to identify those area-based requirements that could be remotely monitored. The 
Commission also informally assessed the use of Sentinel data for monitoring 
requirements under agri-environment-climate measures. As Member State authorities 
design agri-environment-climate schemes and these vary significantly within and 
between Member States, the Commission carried out this informal analysis for a 
sample of paying agencies. It found that many requirements are too complex for 
monitoring with Sentinel data alone (see Table 4). The Commission’s initial analysis of 
the potential applicability of checks by monitoring for cross-compliance, show that 
many requirements under GAEC can be monitored, but currently, out of the seven 

18  The full list of GAECs and SMRs is in Annex II of Regulation (EU) 1306/2013. 

19   Commission Implementing Regulation (EU) 2019/1804 of 28 October 2019 amending 

Implementing Regulation (EU) 809/2014 as regards amendments of aid applications or 
payment claims, checks in the integrated administration and control system and the control 
system in relation to cross compliance. 

 
                                                      
40 

current GAEC standards, only one is considered fully monitorable (with limited 
exceptions). None of the current three SMRs are fully monitorable. 

Table 4 – Scope for monitoring cross-compliance requirements and rural 
development agri-environment-climate eligibility conditions using 
Sentinel data 

Can currently be monitored using 
Sentinel alone 

Cannot currently be monitored using 
Sentinel alone 

Presence of green cover during certain 
time periods 

Crop rotation 

Buffer strips (> 20 m wide) 

Ban on burning arable stubble 

Retention of landscape features (hedges, 
trees in line, groups of trees, etc.) 
depending on their size/width 

Mowing of grassland in a certain period 
(e.g. 2 weeks) 

Ban on tillage 

Buffer strips (< 20 m wide)  

Ban on the use of pesticides on buffer 
strips 

Ban on cutting of hedges and trees 
during the bird breeding/nesting 
season 

Retention of landscape features 
(ditches, isolated trees, traditional 
stone walls)  

Cultivation-free strips and flower strips 
of limited size 

Removal of hay bales after mowing 

Control of invasive species 

Source:  ECA based on Commission documents and discussions. 

67 With a view to designing the next generation of Sentinel satellites (after 2030), 
the Commission is responsible for collecting user requirements and providing these to 
the ESA. The requirements gathered show a demand for thermal data, with a similar 
spatial and temporal resolution as for Sentinel 2, as well as higher spatial resolution of 
the existing systems. Currently, one of the future high-priority missions being 
considered by the ESA would carry a high-resolution thermal infrared sensor to 
provide observations of land-surface temperature with high temporal frequency20. 
Such a sensor could detect water stress in plants and thus be useful for monitoring 

20   https://www.esa.int/Our_Activities/Observing_the_Earth/Copernicus/Candidate_missions  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
41 

irrigation, tracking illegal water abstraction or for adjusting irrigation quantities in 
smart farming. 

Paying agencies do not yet use the monitoring approach for cross-
compliance checks and rural development agri-environment climate 
schemes  

68 In 2019, none of the paying agencies implemented the checks by monitoring 
approach for cross-compliance and rural development agri-environment schemes. The 
paying agencies we visited did not plan to extend the checks by monitoring to rural 
development agri-environment-climate schemes. For cross-compliance, they indicated 
that they might monitor some of the requirements (such as the ban on stubble burning 
or the presence of minimum soil cover) in the future. Figure 14 shows, according to 
our survey, proportions of paying agencies planning to use Copernicus Sentinel data in 
2020 for monitoring agri-environment-climate measures and certain cross-compliance 
requirements. 

Figure 14 – Intended use of Copernicus Sentinel data for systematic 
checks on cross-compliance and agri-environment-climate measures 
from 2020 

Source:  ECA survey. 

69 The reasons why paying agencies do not use Copernicus Sentinel data for cross-
compliance checks, as explained by the PAs we visited, is because they cannot monitor 
all cross-compliance requirements remotely (see Table 4) and they will still need to 
carry out field inspections for other requirements. This limits the benefits of moving to 
monitoring. In Denmark, the paying agency considered that to help farmers accept 
checks by monitoring for cross-compliance requirements, sanctions would need to be 
phased in gradually. 

 
 
42 

70 Paying agencies check the adherence of cross-compliance rules (see 
paragraph 03) for a minimum 1 % of farmers. If a farmer has breached some cross-
compliance rules, depending on the extent, severity and permanence of the 
infringement, paying agencies may reduce the aid by between 1 and 5 %, unless the 
infringement is minor and the farmer can remedy the situation. DG AGRI’s Annual 
Activity Report shows that more than 2 % of all EU farmers were inspected for the 
2017 claim year. One in five of the inspected farmers had aid reduced for breaches 
with at least one of the cross-compliance rules. On average, farmers found to have 
breached cross-compliance rules had the aid paid to them reduced by 2.6 %21. In total, 
the sum of such penalties was almost €40 million, which is around 0.07 % of the CAP 
spending. 

71 Figure 15 shows the 3-year average level of reported breaches for three key 
cross-compliance standards that can be monitored remotely. 

Figure 15 – Percentage of paying agencies per level of cross-compliance 
breaches found (average for the period 2015-2017) 

Sources: Commission’s statistics on the Member States’ results of their cross-compliance inspections for 

2015-2017. 

21  DG AGRI; Annual Activity Report for 2018; Annexes; pp. 198-199. 

 
 
 
                                                      
43 

72 In the last year for which information was available (2017), we calculated that 
eighteen paying agencies detected no breaches whatsoever for these three standards 
while fifteen detected levels exceeding 5 % of farmers breaching the conditions in at 
least one of these standards. 

The Commission does not require Member States to use new 
technologies to directly monitor the environmental and climate impact 
of agriculture post-2020 

73 The Commission proposals of June 2018 for the post-2020 CAP contain specific 
environmental and climate objectives. Member States are to address these objectives 
in their CAP strategic plans. 

74 The Commission proposes a number of performance indicators, intended to 
measure progress towards achieving the objectives. The following are our standard 
definitions of performance indicators22 (together with examples in the area of 
agriculture): 

o  Output indicators: measure something produced or achieved by an EU-funded 
project (e.g. number of hectares covered by a ban on spraying plant protection 
products). 

o 

o 

Result indicators: measure the immediate effect of a project or programme upon 
its completion (e.g. share of agricultural land farmed without plant protection 
products). 

Impact indicators: measure the long-term consequences of a completed project 
or programme, which may be socio-economic, environmental or financial (e.g. 
concentration of plant protection residues in surface water). 

22  ECA, Glossary for our Annual report concerning the financial year 2018. 

 
                                                      
44 

75 In previous reports23, we repeatedly noted that the Commission’s result indicator 
measuring the ‘Share of area under greening practices’ was of limited use for 
monitoring the results achieved with greening. In our Opinion No 7/201824 concerning 
the Commission’s post-2020 CAP proposals, we refer to a number of our audit reports 
criticising the current CAP common monitoring and evaluation framework. In Annex I 
to this Opinion, we commented on the pertinence and quality of the proposed 
indicators. Among other issues we noted that, for example, indicators measuring areas 
under climate commitments do not take into account differences in their contributions 
to climate change (each hectare counts equally). This means that due to the different 
Member States’ conditions to which farmers have to adhere, the impact of these 
measures could be completely different. 

76 In its assessment of the post-2020 CAP indicators, the Commission has identified 
three indicators (I.10, I.13 and I.2025) that, together with other sources, can be based 
on Sentinel data. It proposes basing many others on existing surveys/databases 
managed by the Member States (e.g. LPIS), Eurostat (e.g. Land Use/Cover Area frame 
statistical Survey) and the European Environmental Agency. 

23  ECA, Annual report for 2018, paragraph 7.63 and Special report 21/2017: ‘Greening: a more 
complex income support scheme, not yet environmentally effective’, paragraphs 26-33. 

24  ECA, Opinion 7/2018: concerning Commission proposals for regulations relating to the 

Common Agricultural Policy for the post-2020 period, paragraph 72. 

25  COM(2018) 392: Annex I to Proposal for a Regulation of the European Parliament and of 
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) and repealing Regulation (EU) No 1305/2013 of the European 
Parliament and of the Council and Regulation (EU) No 1307/2013 of the European 
Parliament and of the Council. 

 
 
 
 
                                                      
45 

Conclusions and recommendations 

77 According to the Commission and CAP stakeholders, the use of Copernicus 
Sentinel data and other imaging technologies for monitoring area aid has significant 
potential benefits for farmers, for administrations and for the environment (see 
paragraphs 15 to 19). Our audit examined whether the Commission effectively 
encouraged widespread use of these new technologies and whether Member States 
had taken adequate action to deploy them (see paragraphs 20 to 22). 

78 We found that the Commission has encouraged the use of new technologies, 
especially for monitoring direct payment area aid. The legal framework  allowing the 
use of Sentinel data for checking farmers’ area aid applications entered into force in 
May 2018. The legislative changes made in October 2019 clarified many areas of the 
new monitoring approach, but paying agencies are still concerned about the possible 
outcomes of future Commission’s audits, as the rules for the new approach are not as 
detailed as those for the traditional checks. While this provides scope for innovation 
and the Commission has expressed its readiness to hold discussions and find solutions 
if major issues arise, paying agencies expect further guidance from the Commission in 
order to take the right decisions and reduce the risk of future financial corrections. 
Another issue is the complexity of the current CAP  aid measures, as some 
requirements cannot always be monitored remotely (see paragraphs 24 to 30). 

79 Most of the paying agencies in our survey are also concerned about the risk of 
not being able to reach conclusions on a large number of parcels using automation, 
especially if these would have to be followed up with field visits. This could be the case 
for small parcels, as well as for parcels with certain types of activity (e.g. extensive 
grazing). The Commission has taken steps to find solutions for these issues but they 
still need testing in operational environments (see paragraphs 32 to 37). 

80 Moving to checks by monitoring requires significant changes to IT systems and 
not all paying agencies consider that they currently have the necessary resources and 
expertise to do so. The Commission has taken initiatives to facilitate access to Sentinel 
data and digital cloud processing services, but the take-up by the paying agencies for 
operational purposes is still low (see paragraphs 38 to 40). 

81 The Commission has initiated and funded research projects, most of which are 
still ongoing, so the results of these efforts will only be fully visible in the coming years 
(see paragraphs 41 to 44). 

 
46 

82 We found that five Member States have taken action for direct payments, as 15 
of their paying agencies used the new monitoring approach already in 2019, although 
usually only for certain aid schemes and certain groups of farmers (see paragraphs 45 
to 54). Another 13 paying agencies intend to introduce checks by monitoring in 2020, 
but we observed that a number of obstacles currently hamper wider use of the new 
technologies (see paragraphs 55 to 58). 

Recommendation 1 – Promote the checks by monitoring 
approach as a key control system for paying agencies 

The Commission should provide support and incentives to Member States to use the 
checks by monitoring approach in the post-2020 CAP as a key control system by: 

(1)  maintaining a catalogue of documented examples of good technical practice for 
checks by monitoring that paying agencies can customise according to their 
needs;  

(2)  setting up a quality assessment framework for checks by monitoring; 

(3)  providing a platform for exchanges between paying agencies aimed at identifying 
synergies for data processing, data storage, data acquisition, or other related 
services, which would provide mutual benefits and savings. 

Timeframe: December 2021 

83 While Member States can use the checks by monitoring approach for checking 
certain rural development and cross-compliance requirements, most of them will not 
do so before 2021. This is due to the nature of some of these requirements, which are 
not monitorable remotely, but also because paying agencies expect only limited 
benefits in terms of performance and cost savings (see paragraphs 59 to 71). 

84 While the area monitoring system may play an important role in monitoring the 
CAP’s environmental and climate performance, the set of currently proposed 
post-2020 CAP indicators is largely not designed for direct monitoring with Sentinel 
data (see paragraphs 73 to 76). 

 
 
47 

Recommendation 2 – Make better use of new technologies for 
monitoring environmental and climate requirements 

The Commission should: 

(1) 

identify obstacles hindering the uptake of new technologies for checking cross- 
compliance and rural development requirements and develop an action plan to 
remove them where this is cost-effective; 

(2)  use, and promote the use of, information coming from the new technologies to 
provide better insight into the policy performance of the post-2020 CAP. 

Timeframe: December 2021 

This Report was adopted by Chamber I, headed by Mr Nikolaos Milionis, Member of 
the Court of Auditors, in Luxembourg at its meeting of 8 January 2020. 

For the Court of Auditors 

Klaus-Heiner Lehne 

President  

 
 
 
 
 
 
48 

Acronyms and abbreviations 

AMS: Area monitoring system 

BPS: Basic payment scheme 

CAP: Common Agricultural Policy 

DG AGRI: Directorate-General for Agriculture and Rural Development 

DIAS: Data and information access services 

ECA: European Court of Auditors 

ESA: European Space Agency 

EU: European Union 

GAEC: Good agricultural and environmental condition 

GNSS: Global Navigation Satellite Systems 

GROW: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 

GSAA: Geospatial Aid Application 

IACS: Integrated Administration and Control System 

IT: Information technology 

JRC: Joint Research Centre 

LPIS: Land parcel identification system 

Sen4CAP: Sentinels for the Common Agricultural Policy  

SMR: Statutory management requirements 

VCS: Voluntary coupled support  

YFS: Young farmer scheme 

 
 
 
49 

Glossary 

Agri-environment-climate commitment (measure): A practice, going beyond the usual 
environmental requirements, which farmers can choose to apply and for which they 
receive a payment from the EU budget. 

Area monitoring system (AMS): Technology for the systematic observation, tracking 
and assessment of agricultural activities using Copernicus Sentinels satellite data or 
equivalent. 

Checks by monitoring: A substitute for on-the-spot checks, involving the systematic 
observation, tracking and assessment of eligibility criteria and obligations using 
Copernicus Sentinel data. 

Cloud mask: A filter to exclude cloud-contaminated pixels from a satellite image. 

Conformity clearance procedure: The process whereby the Commission verifies 
whether a Member State has made correct use of the agricultural funds at its disposal 
and has operated its management and control systems effectively. In the case of an 
infringement, the procedure may result in the Member State being required to make a 
repayment. 

Drone: An unmanned aircraft that is controlled remotely and can take photographs. 

Geospatial aid application (GSAA): An online tool for submitting area-based claims for 
agricultural aid. 

Geotagging: The process of adding geographical (and possibly temporal) metadata – 
obtained by the device’s in-built global navigation satellite system – to media, such as 
a photograph.  

Greening: The adoption of agricultural practices which benefit the climate and the 
environment. Also commonly used to refer to the related EU support scheme. 

Land parcel identification system (LPIS): A database of agricultural land in the 
Member States, used in the payment of direct aid under the common agricultural 
policy and in eligibility checks on farmers' claims. 

Machine learning: an application of artificial intelligence in which computer systems 
use algorithms and statistical models to improve their performance of a specific task 
(such as image classification) without being programmed to that end. 

 
50 

Marker: a characteristic change of the satellite signal over time that can be linked to a 
land cover event (such as fast vegetation growth or appearance of dry vegetation). 

Pixel: the smallest unit of an image that can be displayed on a digital device. 

Smart farming: the use of modern technology for tracking, monitoring, automating 
and analysing operations to increase the quantity and quality of agricultural products.  

Spatial resolution: the level of detail that can be detected by a satellite sensor or 
displayed in a satellite image, expressed in (centi)metres per pixel. 

 
 
 
REPLIES OF THE COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN 
COURT OF AUDITORS 

“USING NEW IMAGING TECHNOLOGIES TO MONITOR THE COMMON 
AGRICULTURAL POLICY: STEADY PROGRESS OVERALL, BUT SLOWER FOR 
CLIMATE AND ENVIRONMENT MONITORING” 

EXECUTIVE SUMMARY 

I. The Commission is fully committed to continue simplifying and modernising one of the first and 
largest EU policies, the Common Agricultural Policy (CAP), and welcomes the ECA’s report.   

This highly innovative approach of checks by monitoring is based on an automated analysis of data 
from  Copernicus  Sentinels  satellites  to  determine  the  eligibility  of  beneficiaries  for  CAP  payments 
thus  substituting  resource-consuming  inspections  on  farm.  Follow-up  methods  using  other  new 
technologies  (such  as  geotagged  photos)  are  foreseen  in  case  of  inconclusive  satellite  evidence. 
Checks  by  monitoring  allows  for  alert  messages  to  farmers  and  offers  them  the  possibility  to  take 
corrective action to meet the eligibility requirements and receive payments. 

In order to fast-track the uptake of new technologies, Commission services invested significant efforts 
in providing the legal and technical framework for Member States to adopt “checks by monitoring”  
approach. The Commission offered guidance and hands-on training to the early adopters, as well as 
financial  support  for  the  on-boarding  of  the  Copernicus  Data  and  Information  Access  Services 
(DIAS). 

The use of the checks by monitoring in 2019 by five Member States under the current CAP has to be 
seen as an initial phase, on which the future Area Monitoring System will be based (foreseen under 
the proposed legal framework for the post 2020 CAP).  

The latest information from Member States implementing the checks by monitoring are positive and 
reassuring.  In  many  cases,  the  negatives  anticipated  before  the  start,  have  shown  not  be  a  great 
concern. 

II. Sentinel 1A, Sentinel 2A, Sentinel 1B and Sentinel 2B were launched respectively on 3 April 2014, 
25 June 2015, 25 April 2016 and 7 March 2017. After few months of commissioning periods starting 
from these launch dates, each of the Sentinel satellite has been providing in operational mode Earth 
observation data distributed under the free, full and open Copernicus data policy.  

VII. The Commission understands checks by monitoring as a highly innovative process which calls 
for  a  gradual  extension  in  the  scope  of  the  measures  and  requirements  covered,  building  on  the 
experience gathered. The amendment to Implementing Regulation (EU) 809/2014 was only adopted 
in October 2019. This creates the legal basis to start implementing checks by monitoring for Cross-
compliance. 

So  far,  six  Member  States  have  implemented  pilot  studies  in  2019  for  Cross-compliance  checks  by 
monitoring other than to carry out eligibility checks for direct payment area aid. 

The  Commission  expects  further  adherence  from  Member  States  to  the  checks  by  monitoring  for 
cross-compliance and for Rural Development area based measures. 

VIII. The Commission accepts the recommendations. 

EN 

1 

  EN 

 
 
 
 
 
 
 
INTRODUCTION 

3.  Regulation  (EU)  No  1306/2013  carries  the  principle  that  there  is  a  link  through  the  system  of 
Cross-compliance (CC) between full receipt of CAP support by farmers and respect of a set of basic 
rules related to the three areas of public expectations on environment, health and animal welfare. 

11. The importance of the 'Malta declaration' is also in triggering the shift, to the extent possible, from 
control  to  prevention.  Using  new  technologies  and  a  constant  e-monitoring  of  agricultural  activities 
provides  paying  agencies  with  information  that  can  be  used  to  advise  and  foster  compliance  with 
eligibility  rules,  in  a  preventive  and  pro-active  way,  rather  than  imposing  sanctions  ex-post.  This 
supportive  aspect  was  key  to  subsequent  Commission  actions  and  one  of  the  guiding  principles  for 
amending the legal framework to enable checks by monitoring. 

17.  One  of  the  decisive  reasons  to  start  checks  by  monitoring  is  the  ability  to  prevent  penalties  by 
informing  the  beneficiary  of  potential  non-compliances  and  allowing  for  remedial  actions.  With 
checks  by  monitoring,  beneficiaries  have  the  possibility  to  amend  the  aid  application  based  on 
continuously updated information on the activities on the farm and a dialogue with the paying agency 
in  charge.  This  option  is  not  available  with  the  classical  control  approach.  After  a  classical  field 
inspection, reductions and penalties are applied for non-compliances detected. 

19.  It  is  feasible  to  envisage  situations  where  Member  States  provide  services  without  the  need  to 
grant ‘access to their data’. This is for example foreseen in the context of the Area Monitoring System 
–  which  is  a  mandatory  Integrated  Administration  and  Control  System  (IACS)  element  in  the 
Commission's post-2020 CAP proposal. 

OBSERVATIONS 

25. The service responsible for clearance of accounts was involved at all stages of the introduction of 
the checks by monitoring. When Member States presented their proposals, the audit unit was present 
as to answer any questions they may have on the procedure applied in the conformity audits. 

26. In its letters to paying agencies implementing checks by monitoring in 2019, the Commission did 
not provide any upfront guarantees but rather expressed its readiness to hold discussions and to find a 
solution in case of systemic issues reported in good time. 

27.  The  Commission  does  not  approve  the  control  methodologies.  It  fixes  general  objectives  and 
provides  guidance.    Nonetheless,  the  Commission  provided  a  certain  assurance  in  that  the  methods 
used  for  checks  by  monitoring  were  discussed,  as  confirmed  in  letters  of  comfort  by  the  Director 
General, indicating potential issues. 

28. The Commission notes that the general CAP rules on recoveries apply to transactions subject to 
checks  by  monitoring.  This  means  that  undue  payments  must  be  recovered,  irrespective  of  whether 
the traditional approach or Checks by Monitoring is applied. The Land Parcel Identification System 
(LPIS)  update  cycle  together  with  the  compulsory  retroactive  recovery  procedures  ensure  the 
detection and follow-up of overpayments. 

From  the  outset,  the  Commission  announced  that  the  acceptable  levels  of  false  red  and  false  green 
errors would be revisited. From the experience in 2019, and strengthened by the information coming 
from the industry, the Commission will be in a position to revise the values for 2020. 

29.  The  development  of  a  Quality  Assessment  (QA)  framework  requires  sufficient  experience  with 
the  method  in  question.  Given  that  the  legal  framework  for  checks  by  monitoring  is  only  available 
since  May  2018,  and  given  that  there  was  only  one  paying  agency  implementing  Checks  by 
Monitoring in 2018, it is understandable that detailed QA instructions are still being finalised. 

EN 

2 

  EN 

 
 
 
30. While checks by monitoring make use of Sentinel data for automated monitoring of agricultural 
activities  and  conditions,  it  also  provides  Member  States  with  the  possibility  to  use  other  new 
technologies – such as geo-tagged photos – for the follow-up of inconclusive parcels. 

All the Greening elements listed in table 1 can be handled with geo-tagged imagery in the context of 
follow-ups  permitted  (for  parcels  that  were  inconclusively  monitored  with  Sentinel  data)  under  the 
Checks by Monitoring approach. 

33. The Commission notes that the experience of 2019 shows that the number of yellow parcels, and 
the additional work for the paying agencies are not as high as anticipated by the Member States. 

39. Although not used in operational mode, the Data and Information Access Services (DIAS) were 
effectively tested by some paying agencies in the frame of this initiative. It led to hands-on experience 
with  systematic  analysis  of  Sentinel  data  in  different  cloud  environments  and  new  developments. 
Paying agencies and the Commission gained valuable experience and the feedback is positive. Some 
Member States are expressing their willingness to participate to this scheme. It must be emphasised 
that the choice of IT infrastructure and related procurement are usually made after thorough analysis 
with  often  long  investment  cycles,  in  particular  when  Member  States  have  already  invested  in  their 
own infrastructure. 

40. The DIAS are, as indicated, a very recent initiative making a departure from the traditional access 
to  the  data  and  needing  some  time  to  establish  itself.  In  view  of  the  ever  increasing  volumes  of 
Sentinel  data  archive,  moving  Sentinel  data  to  users  creates  bottlenecks,  consumes  large  amount  of 
network  bandwidth  and  constrains  users  to  manage  themselves  these  data  and  the  infrastructure  to 
process them. The modern alternative is to bring the users’ algorithms to the data and allow the user to 
set up their processing chain and value-adding services on top of data lakes. The DIAS have been set 
up following this new paradigm. The users can then build communities or businesses on top of these 
DIAS and share software and knowledge with their own users. As new initiatives, the DIAS need to 
make their services and business model better known and understood by users. They are moving in a 
competitive  environment  and  have  the  freedom  to  adapt  themselves  to  satisfy  their  potential  users’ 
needs.  The  transition  from  privately  owned  infrastructure  to  public  cloud  services  changes  the 
procurement  and  cost  models  and  users  are  likely  be  still  dependent  on  already  procured 
infrastructures.  However  the  collocation  of  Copernicus  data,  storage,  processing  capacities  and 
software for the benefit of users is a must have for the years to come. 

46.  The  Commission  welcomes  this  very  quick  progress  in  the  uptake  of  an  innovative  technology 
considering the highly regulated environment of controls of CAP payments. 

49.  The  Commission  points  out  that  there  is  no  legal  requirement  for  paying  agencies  to  perform 
follow up visits on conclusively non-compliant (red) parcels. 

60.  Article  68  of  the  Commission  proposal  for  Regulation  on  the  financing,  management  and 
monitoring of the common agricultural policy and repealing Regulation (EU) No 1306/2013 stipulates 
that  Member  States  shall  set  up  and  operate  an  area  monitoring  system.  "Area  Monitoring  System" 
means  a  procedure  of  regular  and  systematic  observation,  tracking  and  assessment  of  agricultural 
activities and practices on agricultural areas by Copernicus Sentinels satellite data or other data with 
at least equivalent value. 

61. The amendment to Implementing Regulation (EU) 809/2014 was only adopted in October 2019, 
which also allows Member States to carry out checks by monitoring for Cross-compliance. 

Six  Member  States  have  implemented  pilot  studies  in  2019  for  Cross-compliance  checks  by 
monitoring other than to carry out eligibility checks for direct payment area aid. 

The  Commission  invites  all  Member  States’  paying  agencies  to  biannual  workshops  to  present  the 
latest information on the application of these new monitoring technologies. 

EN 

3 

  EN 

 
 
 
65.  Based  on  the  technical  capabilities  at  that  time,  the  Commission’s  work  began  with  the  use  of 
checks by  monitoring for area-based direct payment schemes, rather than for Cross-compliance and 
rural  development  agri-environmental  schemes,  where  more  specific  and  qualitative  requirements 
need to be considered. Hence, in 2019 checks by monitoring were extended to Cross-compliance. 

66.  The  table  of  proposed  Good  Agricultural  and  Environmental  Condition  (GAEC)  standards  (as 
listed  in  Annex  III  of  the  proposal  CAP  strategic  plans  regulation)  proposes  ten  future  GAEC 
standards , five of which are considered monitorable (1,3,7,8 & 9) (with some limitations). Four other 
GAEC  standards  will  be  at  least  partially  monitorable  (one  or  more  sub-requirements  are 
monitorable). The remaining standard, GAEC 5, will be delivered via an IT tool, which will facilitate 
automated  checks,  without  a  field  visit.  Hence,  this  standard  can  be  considered  fully  monitorable 
(although not via Sentinel data).  

Concerning  the  Statutory  Management  Requirements  (SMRs),  there  may  be  certain  area-based 
elements  that  will  be  monitorable,  depending  on  size/nature  of  the  measures  in  the  Nitrates  Action 
Programme  (NAP)  or  Management  Plan  (MP)  under  a  nature  Directive.  Hence,  these  SMRs  are  at 
least partially monitorable. 

67. Land Surface Temperature monitoring (LSTM) is one of the high-priority missions of Copernicus 
designed  by  the  Commission  and  European  Space  Agency  (ESA).  The  LSTM  has  been  proposed 
under the Expansion missions to be launched post 2025. The specifications of the mission have been 
defined  with  international  experts,  including  from  the  Commission.  Considering  the  technological 
possibilities  and  the  Policy  User  Requirements,  the  spatial  resolution  envisaged  is  50  meters.  Full 
interoperability with S2 and S2 Next Generation will be ensured. 

68. The technical capabilities of the current technology limits full monitorability to one GAEC under 
the  current  Cross-compliance  rules  and  then  partially  to  four  of  the  other  seven,  where  sub 
requirements may be monitorable. 

The  Commission  also  expects  that  eventually  monitoring  will  be  extended  to  Rural  Development 
area-based measures.  

69.  Checks  by  monitoring  cannot  verify  all  the  Cross-compliance  requirements,  for  example:  food 
safety, animal identification and animal welfare. 

74.  In  its  proposal  for  the  post-2020  CAP,  the  Commission  proposed  indicators  on  the  following 
basis: 

•  Output indicators: serve to link expenditure to outputs. They are used for annual performance 

clearance. 

•  Result indicators: are used to link outputs to specific objectives, for setting targets (realised by 
approved interventions) and for monitoring implementation progress (performance review). 
Impact  indicators:  contribute  to  evaluating  performance  of  the  CAP  in  relation  to  CAP-
specific objectives (mid-term and ex-post evaluation). 

• 

75.  Our  future  CAP  indicators  are  pertinent  and  relevant  for  measuring  farmers’  commitments 
towards  mitigating  climate  change.  However,  measuring  the  actual  contribution  of  the  CAP  to 
emission reductions is too complex and not required to Member States in the annual report. 

76. In addition to these three impact indicators, which can be partly based on Sentinel and Copernicus 
data, the Commission is asking Member States to put in place a system to collect reliable and accurate 
(output and result) data on CAP implementation and satellites can help Member States to do it. 

EN 

4 

  EN 

 
 
 
 
 
 
CONCLUSIONS AND RECOMMENDATIONS 

77. The Commission welcomes the ECA’s conclusions and will continue working to foster the uptake 
of  new  technologies  by  both  administrations  and  farmers.  Efforts  to-date  has  made  possible  the 
significant  achievements  made  so  far:  the  new  technologies  are  gaining  ground  and  real-life 
implementation  is  well  on  track  in  several  Member  States.  Further  progress  is  expected,  also  as  a 
result of the Commission putting in place actions to fulfil the recommendations proposed by the ECA 
in this Special Report. 

78. Changes in the legislation as well as guidance provided to Member States were prepared in close 
cooperation  between  the  policy  and  audit  experts  of  the  Commission.  Hence,  the  need  to  provide 
flexibility was balanced with ensuring minimum risk of potential financial corrections. 

79.  The  results  from  those  Member  States  actually  implementing  checks  by  monitoring  in  2019, 
demonstrate  that  the  risk  of  a  high  number  of  inconclusive  results  did  not  materialise.  This 
information, presented by the ECA in Table 3, was available only after the ECA carried out its survey 
(i.e. at the end of claim year 2019).  

82. The Commission encourages Member States to take up the new monitoring approach by gradually 
phasing-in, extending the scope of measures and groups of farmers covered. 

The results from the Member States implementing the new monitoring approach are very positive and 
did not confirm the obstacles indicated by the paying agencies in the survey. 

Recommendation 1 – Promote the  checks by  monitoring approach as a key control system for 
paying agencies  

Since  the  future  CAP  foresees  an  increased  level  of  subsidiarity  given  to  Member  States,  the 
Commission understands the ECA’s recommendation 1 as within the limits of subsidiarity. 

(1) The Commission accepts the recommendation.  

The Commission will provide a facility for  Member States to enable the exchange  of best practices 
and technical solutions implemented by paying agencies. 

(2) The Commission accepts the recommendation. 

Efforts to define a QA system for Checks by Monitoring are underway. 

(3) The Commission accepts the recommendation.  

This  should  be  done  using  existing  services,  such  as  DIAS,  which  are  providing  the  digital 
environment allowing communities to share algorithms, software, knowledge and data between their 
users.  

83. The technical capabilities of the current technology limit full monitorability to one GAEC under 
the  current  Cross-compliance  rules  and  then  only  partially  to  four  of  the  other  seven,  where  sub 
requirements may be monitorable. 

The  legal  act  allows  now  Member  States  to  start  implementing  checks  by  monitoring  to  Cross-
compliance  and  many  Member  States  are  in  a  study  phase  assessing  the  impact  of  checks  by 
monitoring on the Cross-compliance control system. 

84. Sentinel is suitable for direct monitoring of certain output and result indicators by Member States. 

Copernicus provides opportunities for monitoring of CAP indicators. 

Recommendation 2 – Make  better  use  of  new  technologies  for  monitoring  environmental  and 
climate requirements 

EN 

5 

  EN 

 
 
 
 
(1) The Commission accepts the recommendation.  

The  Commission,  in  close  cooperation  with  Member  States,  will  identify  the  main  obstacles  in 
extending the scope of checks by monitoring and propose adequate legal and technical solutions. 

(2) The Commission accepts the recommendation. The Commission will work with Member States to 
foster  the  use  of  new  technologies  for  policy  monitoring  and  implementation,  allowing  all 
stakeholders in the agricultural sector to harvest the benefits of innovation. 

EN 

6 

  EN 

 
 
 
 
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 Sustainable use of natural 
resources, headed by ECA Member Nikolaos Milionis. The audit was led by ECA 
Member Phil Wynn Owen, supported by Gareth Roberts, Head of Private Office 
Ramona Bortnowschi and Olivier Prigent, Private Office Attachés; Richard Hardy, 
Principal Manager; Jindrich Dolezal, Head of Task; Els Brems, Deputy Head of Task; 
Paulo Braz, Antonio Caruda Ruiz, Arfah Chaudry, Michail Konstantopoulos,  
Anne Poulsen, Bruno Scheckenbach and Pekka Ulander, Auditors. Richard Moore 
provided linguistic support. 

From left to right: Pekka Ulander, Arfah Chaudry, Richard Moore, Jindrich Dolezal, 
Richard Hardy, Ramona Bortnowschi, Phil Wynn Owen, Olivier Prigent.

 
 
 
Timeline 

Event 

Date 

Adoption of Audit Planning Memorandum (APM) / Start of audit 

27.3.2019 

Official sending of draft report to Commission  
(or other auditee) 

14.11.2019 

Adoption of the final report after the adversarial procedure 

8.1.2020 

Commission’s (or other auditee’s) official replies received in all 
languages 

24.1.2020 

 
 
 
 
 
 
 
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PDF 
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ISBN 978-92-847-4244-8 
ISBN 978-92-847-4229-5 

ISSN 1977-5679 
ISSN 1977-5679 

doi:10.2865/46869 
doi:10.2865/75782 

QJ-AB-20-001-EN-N 
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2 

New imaging technologies, such as the EU-owned 
Copernicus Sentinel satellites, have the potential to be a 
game changer in monitoring the Common Agricultural Policy 
while also providing benefits for farmers and for the 
environment. We found that the Commission has 
encouraged the use of new technologies by Member State 
paying agencies, especially for monitoring direct payment 
area aid. In 2019, 15 paying agencies in five Member States 
used Sentinel data to check aid applications, but a number of 
obstacles currently hamper wider use of new technologies 
by paying agencies. We recommend that the Commission 
mitigate these obstacles and make better use of the new 
technologies for monitoring environmental and climate 
requirements. 

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