COMMISSION STAFF WORKING DOCUMENT EVALUATION impact of the CAP on biodiversity, soil and water (natural resources)
Date: 2021-12-17
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: EU environmental policy, biodiversity, common agricultural policy, environmental impact, environmental protection, land use, management of resources, soil resources, water management in agriculture, water resources

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.12.2021  SWD(2021) 424 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  impact of the CAP on biodiversity, soil and water (natural resources) {SWD(2021) 425 final}  
 
 
Table of contents 

1. 
1.1. 

Introduction ....................................................................................................................................... 3 
Purpose and scope ............................................................................................................................... 3 

2. 
Background to the intervention ....................................................................................................... 5 
2.1.  Description of the intervention and its objectives ............................................................................... 5 
2.2.  Baseline and points of comparison ................................................................................................... 11 

3. 
Implementation / state of play........................................................................................................ 13 
3.1.  Description of the current situation ................................................................................................... 13 

4. 
4.1. 
4.2. 

Method ............................................................................................................................................. 21 
Short description of methodology ..................................................................................................... 21 
Limitations and robustness of findings ............................................................................................. 22 

Analysis ............................................................................................................................................ 23 
5. 
Effectiveness ..................................................................................................................................... 23 
5.1. 
5.2. 
Efficiency .......................................................................................................................................... 61 
5.3.  Coherence ......................................................................................................................................... 67 
5.4.  Relevance .......................................................................................................................................... 75 
EU Added Value ............................................................................................................................... 78 
5.5. 

Conclusions ...................................................................................................................................... 81 
6. 
Effectiveness ..................................................................................................................................... 82 
6.1. 
6.2. 
Efficiency .......................................................................................................................................... 85 
6.3.  Coherence ......................................................................................................................................... 86 
6.4.  Relevance .......................................................................................................................................... 87 
EU added value ................................................................................................................................. 88 
6.5. 
Lessons learned ................................................................................................................................. 88 
6.6. 

Annex 1: Procedural information ............................................................................................................. 91 

Annex 2: Stakeholder consultation............................................................................................................ 93 

Annex 3: Methods and analytical models ............................................................................................... 100 

Annex 4: Tables and figures complementing chapter 2 ........................................................................ 103 

Annex 5: Benchmark: the situation prior to the 2014-2020 CAP ......................................................... 105 

Annex 6: Information complementing chapter 3 ................................................................................... 107 

Annex 7: Tables and figures complementing chapter 5 ........................................................................ 109 

1 

 
 
AECMs 

Agri–environment-climate measures 

Glossary 

AIRs 

AKIS 

ANCs 

BPS 

CAP 

CMEF 

EAFRD 

EFA 

EIP 

ENRD 

ESPG 

EU 

EUR 

FADN 

FAS 

GAECs 

GHG 

HNV 

IACS 

NGO 

RDP 

SAPS 

SFS 

SMRs 

UAA 

Annual implementation reports on the EAFRD 

Agricultural knowledge and innovation system 

areas facing natural or other specific constraints 

Basic payment scheme 

Common agricultural policy 

Common monitoring and evaluation framework 

European Agricultural Fund for Rural Development 

Ecological focus area 

European  Innovation  Partnership  for  Agricultural  Productivity 
and Sustainability 

European Network for Rural Development 

Environmentally sensitive permanent grassland 

European Union 

Euro (currency of the Eurozone) 

Farm Accountancy Data Network 

Farm advisory service 

Good agricultural and environmental conditions 

Greenhouse gas 

High nature value 

Integrated administration and control system 

Non-governmental organisation 

Rural development programme 

Single area payment scheme 

Small farmers scheme 

Statutory management requirements 

Utilised agriculture area 

2 

 
 
 
 
1.  INTRODUCTION 

1.1.  Purpose and scope 

The  2013  reform  of  the  common  agricultural  policy  (CAP)  aimed  to  improve  the 
targeting,  efficiency  and  coherence  of  policy  instruments  by  addressing  the  long-term 
objectives of (i) viable food production, (ii) sustainable management of natural resources 
and climate action and (iii) balanced territorial development (as set out in Article 110(2) 
of Regulation (EU) No 1306/2013, the ‘Horizontal Regulation’)1.  

Article  110(5)  of  the  Horizontal  Regulation  obliges  the  Commission  to  present,  by 
31 December 2021, an assessment of the CAP’s performance over the period 2014-2020. 
The purpose of this evaluation is to assess the impact that relevant CAP instruments and 
measures have had on biodiversity, soil and water and therefore to determine the extent 
to  which  they  have  helped  achieve  the  overarching  policy  objective  of  sustainably 
managing natural resources2.  

The evaluation is particularly relevant in light of the objectives set out in the  European 
Green  Deal3,  notably  the  EU  biodiversity4  and  farm  to  fork5  strategies.  The  increased 
emphasis on agro-environmental targets, combined with the need for a resilient, safe and 
sustainable  food  system  ensuring  food  security,  requires  a  better  balance  between 
farming  and  nature.  This  means  an  EU  farm  sector  that  protects  the  environment, 
preserves biodiversity and provides access to healthy, affordable and sustainable food. At 
the same time, it also has to generate a fair economic return for farmers. The sustainable 
management of natural resources remains a key CAP general objective6. 

The  measures  covered  by  the  evaluation  include  the  full  spectrum  of  relevant 
instruments set out in the basic 2014-2020 CAP Regulations on Direct Payments7, Rural 
Development8, the Common Market Organisation9 and the Horizontal Regulation, which 
target the sustainable management of natural resources. 

1   Regulation (EU) No 1306/2013 of the European Parliament and of the Council of 17 December 2013 
on  the  financing,  management  and  monitoring  of  the  common  agricultural  policy,  OJ  L  347, 
20.12.2013, p. 549–607.  

2   Complementing the  evaluations  of the  greening and forestry  measures of the CAP, and  of the  CAP’s 
performance in achieving the objectives on ‘climate action’. The evaluation of the CAP with respect to 
‘viable food production’ and ‘balanced territorial development’ are covered in separate evaluations.  

3   https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en. 
4   https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/actions-being-taken-eu/EU-

biodiversity-strategy-2030_en. 

5   https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/actions-being-taken-

eu/farm-fork_en. 

6   Three out of the nine key objectives of the European Commission proposal on the CAP for the period 
2021-2027  address  the  environment  and  climate,  notably  environmental  care,  the  preservation  of 
landscapes  and  biodiversity,  and  climate  change  action.  For  more 
information,  visit: 
https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/future-
cap/key-policy-objectives-future-cap_en. 

7   Regulation (EU) No 1307/2013 of the European Parliament and of the Council of 17  December 2013 
establishing  rules  for  direct  payments  to  farmers  under  support  schemes  within  the  framework  of  the 
common agricultural policy, OJ L 347, 20.12.2013, p. 608–670. 

8   Regulation (EU) No 1305/2013 of the European Parliament and of the Council of 17 December 2013 
on support for rural development by the European Agricultural Fund for Rural Development (EAFRD),  
OJ L 347, 20.12.2013, p. 487–548. 

3 

 
 
                                                      
The  evaluation  covers  the  geographical  area  of  the  European  Union  of  28 Member 
States, including the United Kingdom,  as  it was  a member of the EU  during the 2014-
2020  period  evaluated10.    The  evaluation  period  corresponds  to  the  implementation 
period of the 2014-2020 CAP, which started on 1 January 2015 for direct payments and 
1 January 2014 for other measures. For analytical reasons, the evaluation uses the 2007-
2013 period as reference. 

The  evaluation  covers  all  evaluation  criteria,  assessing  the  effectiveness,  efficiency, 
relevance, coherence and EU value added of the measures covered by the evaluation. 

This  Commission  staff  working  document  is  primarily  based  on  the  external 
evaluation  support  studies  on biodiversity11,  soil12  and water13  and  the  responses  the 
Commission  received  to  its  corresponding  public  consultation14.  It  also  draws  on 
existing  evaluations,  including  on  payments  for  agricultural  practices  beneficial  for  the 
climate  and 
the  environment  (‘greening’)15,  on  forestry  measures  under  rural 
development16  and  the  impact  of  the  CAP  on  climate  change  and  greenhouse  gas 
emissions17.  The  evaluation  takes  into  account  additional  analysis  and  complementary 
data  from  various  sources,  as  referenced  throughout  the  document.  In  the  subsequent 
chapters,  any  reference  to  analyses,  interviews,  findings,  etc.  comes  from  the  support 
studies, unless otherwise indicated. 

The evaluation contributes to the assessment of the CAP’s design and performance 
in  addressing  the  objective  of  sustainably  managing  natural  resources,  to  ensure  it 
remains fit for purpose. Its findings will also  provide information on the Commission’s 
support to the Member States in the ongoing development of their strategic plans for the 
next CAP period.  

9   Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 
establishing a common organisation of the  markets in agricultural products, OJ L 347, 20.12.2013, p. 
671–854. 

10   For  the  purposes  of  the  evaluation,  which  covers  the  period  2014-2020,  the  United  Kingdom  is 
considered  a  member  of  the  European  Union  (EU-28).  The  United  Kingdom  withdrew  from  the 
European  Union  on  1  February  2020,  entering  a  transition  period  until  31  December  2020,  during 
which Union law, with a few exceptions, continued to be applicable to and in the United Kingdom. 
11   Alliance  Environnement  (2019)  Evaluation  support  study  on  the  impact  of  the  CAP  on  habitats, 
https://ec.europa.eu/info/food-farming-fisheries/key-

landscapes, 
policies/common-agricultural-policy/cmef/sustainability/impact-cap-habitats-landscapes-
biodiversity_en. 

biodiversity. 

Brussels. 

12   EEIG  Alliance  Environnement  (2020)  Evaluation  support  study  on  the  impact  of  the  CAP  on 
sustainable  management  of  the  soil.  Brussels.  https://ec.europa.eu/info/food-farming-fisheries/key-
policies/common-agricultural-policy/cmef/sustainability/impact-cap-sustainable-management-soil_en. 
13   EEIG  Alliance  Environnement  (2019)  Evaluation  support  study  on  the  impact  of  the  CAP  on  water. 
https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

Brussels. 
policy/cmef/sustainability/impact-cap-water_en. 

14   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1951-Evaluation-of-the-impact-

of-the-CAP-on-water/public-consultation. 

15   SWD(2018)478 

https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

policy/cmef/sustainability/payments-agricultural-practices-beneficial-climate-and-environment_en. 

16   SWD(2019)389 

https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

policy/cmef/sustainability/evaluation-staff-working-document-forestry-measures-under-rural-
development_en. 

17   SWD(2021)116  https://ec.europa.eu/info/sites/default/files/food-farming-

fisheries/key_policies/documents/ext-eval-soil-greenhouse-report_2020_en.pdf. 

4 

 
 
                                                                                                                                                              
2.  BACKGROUND TO THE INTERVENTION 

2.1.  Description of the intervention and its objectives 

The  2013  CAP  reform  was  designed  to  address  the  diverse  challenges  facing  the  EU 
agri-food sector at the time. They were:  

 

 

 

economic:  food security  and  globalisation, a declining rate of productivity  growth, 
price volatility, high input prices, deteriorating supply chain position of farmers; 

environmental: resource efficiency, soil and water quality, threats to biodiversity;   

territorial: demographic, socio-economic developments, challenges to rural areas. 

The  2013  CAP  reform  took  place  in  parallel  to  the  discussions  on  the  Europe  202018 
strategy  and  negotiations  on  the  2014-2020  multiannual  financial  framework  (MFF). 
Accordingly,  further  factors  driving  the  2013  CAP  reform  were  to  align  the  2014-
2020 CAP with the goals of the Europe 2020 strategy on smart, sustainable and inclusive 
growth, and to optimise the targeting and efficiency of CAP measures within the 2014-
2020 EU budgetary framework of the MFF.  

Thus, three general objectives were established for the 2014-2020 CAP: 

 

 

 

viable  food  production:  with  a  focus  on  agricultural 
productivity and price stability; 

income,  agricultural 

sustainable  management  of  natural  resources  and  climate  action:  with  a  focus  on 
greenhouse gas emissions, biodiversity, soil and water; 

balanced  territorial  development:  with  a  focus  on  rural  employment,  growth  and 
poverty in rural areas. 

The objectives are targeted by the two pillars of the CAP: pillar I on direct payments and 
market  measures,  financed  by  the  European  Agricultural  Guarantee  Fund  (EAGF),  and 
pillar  II  on  rural  development,  financed  through  the  European  Agricultural  Fund  for 
Rural Development (EAFRD).  

The  environmental  aspects  of  the  CAP  have  been  gaining  prominence  with  subsequent 
reforms,  given  the  challenges  facing  the  environment.  Over  the  last  few  decades, 
agricultural  habitats,  and  to  a  lesser  extent  habitats  in  forests,  have  been  in  decline, 
primarily  due  to  the  effects  of  habitat  conversion,  farms  specialisation  and  agricultural 
production  intensification.  Agriculture  and  forestry  activities  have  an  impact  on  soil 
quality, organic matter content, soil biodiversity and the balance of nutrients in soils, and 
these  activities  result  in  soil  erosion,  compaction,  pollution  and  salinisation.  The  EU 
agricultural sector is dependent on the availability of water resources, but the sector also 
significantly  affects  the  ecological,  chemical  and  quantitative  status  of  waterbodies. 
Agriculture remains one of the most significant pressures affecting the quality, quantity 
and hydromorphologicial status of waterbodies throughout the EU.  

The  CAP  objectives  of  sustainable  management  of  natural  resources  and  climate 
action  were  aimed  to  support  the  headline  biodiversity  target  of  halting  the  loss  of 
biodiversity and the degradation of ecosystem services in the EU by 2020 and restoring 
them as far as feasible. It responded in particular to target 3 of the biodiversity strategy to 

18   https://ec.europa.eu/eu2020/pdf/COMPLET%20EN%20BARROSO%20%20%20007%20-

%20Europe%202020%20-%20EN%20version.pdf. 

5 

 
 
                                                      
202019 which aimed to increase the contribution of agriculture and forestry to maintaining 
include  maintenance  and 
and  enhancing  biodiversity.  Biodiversity  activities 
improvement of landscape elements and support for the conservation of natural reserves 
and wetlands. Sustainable soil management activities in agriculture and forestry such as 
soil  conservation,  amendment,  restoration,  fertilisation  and  health  can  help  to  protect, 
restore  and  improve  soil  quality  and  safeguard  its  natural  functions.  The  sustainable 
management of water in agriculture is gaining even greater importance in the context of 
climate  change;  and  activities  to  limit  pesticide/plant  protection  product  use,  reduce 
water  consumption,  increase  water  use  efficiency,  reduce  runoff  of  nutrients  are 
necessary to reduce the environmental impact of agriculture on water.  

Figure 1 Support for environment and climate in the 2014-2020 CAP 

Source: Directorate-General for Agriculture and Rural Development 

The  2013  CAP  reform  introduced  a  new  combination  of  green  support  measures 
(Figure  1) to address  the pressures  on natural  resources and improve the  environmental 
performance of EU agriculture. This new approach includes:  

 

 

 

a simplified and more targeted cross-compliance, representing the compulsory basic 
layer of environmental requirements and obligations from other legislation to be met 
in order to receive full CAP funding, including statutory management requirements 
(SMR) and good agricultural and environmental conditions (GAECs);   

green  direct  payments  (‘greening’),  accounting  for  30%  of  the  national  direct 
payment  amount  and  rewarding  farmers  for  applying  three  obligatory  agricultural 
practices,  namely  maintenance  of  permanent  grassland,  ecological  focus  areas  and 
crop diversification;  

a  greater focus of the second pillar on sustainability, with  an obligation  of at  least 
30%  of  the  budget  of  each  rural  development  programme  reserved  for  voluntary 
measures  beneficial  for  the  environment  and  climate  (including  agri–environment-
climate  measures  (AECMs),  organic  farming,  Natura 2000  and  Water  Framework 
Directive payments, forestry measures and investments)20. 

19   https://ec.europa.eu/environment/nature/biodiversity/strategy_2020/index_en.htm. 
20   As  well as payments  for areas under natural constraints (ANC),  which  were  found to  make a limited 

contribution to environmental objectives. 

6 

 
 
 
                                                      
To  help  farmers  implement  appropriate  solutions  for  their  specific  situations,  these 
complementary  policy  instruments  are  accompanied  by  related  training  measures  and 
other  support  from  the  farm  advisory  system21  as  well  as  insights  gained  from  the 
innovation  partnership  and  applied  research22.  The  CAP  provides  a  comprehensive 
framework for addressing the objective of sustainable management of natural resources, 
and  considerable  flexibility  for  Member  States  to  implement  the  various  measures  (as 
demonstrated in chapter 3). 

Under cross-compliance, if farmers and other beneficiaries of CAP  area-based support 
violate  EU  law  on  environmental,  public  and  animal  health,  as  well  as  animal  welfare, 
their  CAP  support  may  be  reduced.  The  scope  of  cross-compliance  includes  ‘statutory 
management requirements’ (SMRs), which are obligations covered by EU directives and 
regulations,  such  as  the  Directives  on  nitrates  (Council  Directive  91/676/EEC),  on  the 
conservation  of  wild  birds  (Directive  2009/147/EC)  and  on  the  conservation  of  natural 
habitats  and  of  wild  fauna  and  flora  (Council  Directive  92/43/EEC).  The  scope  also 
includes  standards  for  the  good  agricultural  and  environmental  condition  of  land 
(GAECs), covering water, soil and carbon stock, biodiversity and landscape,  as well as 
the minimum level of maintenance23.  

As  for  the  aim  of  the  greening  obligations  under  pillar  I,  the  crop  diversification 
measure  was  aimed  at  improving  soil  quality;  the  maintenance  of  permanent  grassland 
was  aimed  at  supporting  carbon  sequestration  and  protecting  biodiversity  (habitats)  in 
case of environmentally sensitive grasslands located in Natura 2000 areas; and dedicating 
5% of arable land to areas beneficial for biodiversity (ecological focus areas - EFAs) was 
aimed at safeguarding and improving biodiversity on farms24. 

Pillar II objectives contributing to the sustainable management of natural resources and 
climate action (referred to as ‘priorities for rural development’) include25:  

 

restoring,  preserving  and  enhancing  ecosystems  (priority  4),  with  focus  areas  4A 
(restoring,  preserving  and  enhancing  biodiversity),  4B 
(improving  water 
management), and 4C (preventing soil erosion and improving soil management); 

  a  resource-efficient,  climate-resilient  economy  (priority  5),  with  focus  areas  5A 
(increasing  efficiency  in  water  use  by  agriculture),  5D  (reducing  nitrous  oxide  and 
methane  emissions  from  agriculture),  and  5E  (fostering  carbon  conservation  and 
sequestration in agriculture and forestry). 

Table  1  gives  an  overview  of  pillar  II  measures  that  are  relevant  for  supporting  the 
sustainable management of biodiversity, soil and water, among other objectives.  

21   The  farm  advisory  system  (FAS)  helps  farmers  to  better  understand  and  meet  the  EU  rules  for 
environment,  public  and  animal  health,  animal  welfare  and  the  GAEC.  For  further  information,  visit 
https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/income-
support/cross-compliance/fas_en. 

22   The  European  innovation  partnership  for  agricultural  productivity  and  sustainability  (EIP-AGRI)  was 
created  to  bridge  the  gap  between  innovative  solutions  by  researchers  and  the  uptake  of  new 
technologies by those living and working in rural areas. See https://ec.europa.eu/eip/agriculture/. 
23   The list of SMRs and GAECs is provided in Annex 4: Tables and figures complementing chapter 2.  
24   For  more 

information,  visit  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-

agricultural-policy/income-support/greening_en. 

25   For  more 

information,  visit  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-

agricultural-policy/rural-development_en. 

7 

 
 
                                                      
Table  1  EAFRD  measures  that  may  contribute  to  the  sustainable  management  of  natural 
resources  

MEASURES 

M10: Agri-environment-
climate (AECMs) 

M11: Organic farming 

M12: Natura 2000 & Water 
Framework Directive 

M13: Payments to areas 
facing natural or other 
specific constraints (ANC)26 

M04:: Investments in 
physical assets 

M08: Investments in forest 
areas 

M15: forest-environment 

M01: Knowledge transfer 
and information actions  

M02: Advisory services 

M16: Cooperation 

M07: Basic services and 
village renewal in rural areas 

to 

to 

linked 

improve 

investments 

investment  grant 

BRIEF DESCRIPTION 
This  measure  aims  to  preserve  and  promote  ‘agricultural  practices  that 
make  a  positive  contribution  to  the  environment  and  climate’,  by 
compensating  beneficiaries  for  all  or  part  of  the  additional  costs  and 
income foregone.  
The  measure  provides  support  to  farmers  that  convert  to  or  maintain 
organic farming practices and methods. 
The  measure  provides  annual  per  hectare  compensation  payments  to 
farmers  and  foresters  for  the  additional  costs  and  income  foregone 
resulting  from  the  disadvantages  of  implementing  the  Birds  and  Habitats 
Directives or the Water Framework Directive. 
The measure provides support for farmers to pursue their farming activity 
in  mountain  areas  and  other  areas  facing  natural  or  other  specific 
constraints  (as  designated  in  Article  32  of  Regulation  (EU)  1305/2013). 
The  support  compensates  farmers  for  the  additional  costs  and  income 
foregone resulting from the constraints to agricultural production.  
The 
the  economic  and 
is  designed 
environmental  performance  of  holdings.  This  support  covers  investments 
that improve the overall performance and sustainability of farms, including 
non-productive 
the  achievement  of  agri-
environment-climate objectives; etc. 
Support  under  this  measure  concerns,  among  others,  afforestation  and 
creation  of  woodland,  establishment  of  agroforestry  systems,  investments 
improving forest ecosystems’ resilience and environmental value as well as 
their mitigation potential. 
This  measure  supports  operations  consisting  of  one  or  more  forest-
environment  and  climate  commitments  going  beyond 
the  relevant 
mandatory  requirements  established  by  the  national  forestry  act  or  other 
relevant national law.   
The measure  aims to give  farmers, forest  holders, persons  engaged in the 
food sector and rural small and medium-sized enterprises improved access 
to technical and economic  knowledge and information. It should  increase 
their competitiveness and improve their environmental performance, etc.  
Farm  advisory  services  help  farmers  and  other  actors  of  rural  areas  to 
improve  the  sustainable  management  and  overall  performance  of  their 
holding  (modernisation,  competitiveness,  sectoral  integration,  market 
orientation, innovation, etc.). 
This measure promotes various forms of cooperation involving at least two 
entities,  including  support  for  the  establishment  and  operation  of 
operational groups of the European Innovation Partnership for agricultural 
productivity and sustainability.  
Support under this measure concerns small-scale infrastructure and covers, 
among  others,  management  plans  relating  to  Natura  2000  sites  and  other 
areas  of  high  nature  value,  studies  and  investments  associated  with  the 
maintenance,  restoration  and  upgrading  of  high  nature  value  sites, 
including  environmental  awareness  actions,  increasing  the  environmental 
performance of the settlement. 

26   Member States could allocate up to 5% of their national ceiling for an additional voluntary payment to 
farmers  who  are  entitled  to  the  basic  payment  and  whose  holding  is  located  in  areas  with  natural 
constraints. The payment is granted per eligible hectare in order to offset the additional costs of farming 
in  disadvantaged  areas.  All  Member  States  use  the  scheme  targeting  these  areas  in  their  rural 
development programmes, except for Denmark and Slovenia who implement it in pillar I. 

8 

 
 
 
                                                      
The agri-environment-climate measure (AECM) is a key policy measure used in favour 
of  biodiversity  and  landscapes,  compensating  farmers  (and  sometimes  other  land 
managers)  for  the  additional  costs  and  income  losses  they  incur  when  they  voluntarily 
undertake  agricultural  practices  that  deliver  environmental  benefits  (beyond  the 
beneficiary’s already existing obligations).  

The practices funded by AECM are very wide-ranging and include cultivation practices, 
farm  management,  irrigation/  drainage,  management  of  inputs,  management  of 
landscape,  habitats,  grassland,  high  nature  value  farming,  etc.  AECM  practices  have 
more demanding  and targeted  management requirements (e.g. use of appropriate mixes 
of  species)  than  what  is  required  under  cross-compliance,  the  system  of  green  direct 
payments and any other sources of relevant obligations.  

A  number  of  CAP  instruments  and  measures  not  designed  to  address  the  natural 
resource objective have indirect implications on sustainable management. 

These  include  area-based  decoupled  direct  payments,  coupled  payments  and  the 
operational programmes for fruits and vegetables under the common market organisation 
(Regulation (EU) No 1308/2013).  

The aim of basic direct payments (BPS/SAPS) for the management of natural resources 
is not stated clearly in the legislation, but they help keep afloat less profitable holdings 
that  have  practices  beneficial  for  the  environment  (e.g.  highly  diversified  holdings, 
extensive  grazing  systems,  etc.).  Basic  direct  payments  can  be  of  different  amounts 
depending on the Member State/ region and the historical level of entitlements.  

Voluntary  coupled  support  is  based  on  fixed  areas,  type  of  crops  grown,  and  yield 
and/or  numbers  of  animals,  and  can  be  provided  to  sectors  facing  particular  situations 
where specific types of farming or specific agricultural sectors are particularly important 
for economic, environmental or social reasons. The sectors most supported include beef 
and veal, dairy products, sheep and goat meat, and protein crops.  

Regulation  (EU)  No  1308/2013  set  up  a  common  organisation  of  the  markets  in 
agricultural  products,  establishing  support  measures  among  other  things,  for  the  olive, 
fruit  and  vegetables,  and  wine  sectors.  In  accordance  with  the  Regulation,  operational 
programmes  for  the  fruit  and  vegetable  sector  need  to  include  two  or  more 
environmental  actions,  and  at  least  10%  of  the  expenditure  under  operational 
programmes has to cover environmental actions. 

Outside the CAP, a body of EU environmental legislation and policy instruments (not 
specific to agriculture) set objectives and requirements for the sustainable management 
of  natural  resources  (by  setting  objectives  and  requirements),  in  line  with  the 
7th environmental  action  programme  that  guided  the  EU’s  environment  policy  until 
202027.  

Regarding  biodiversity,  the  Birds  Directive  (2009/147/EC)  and  the  Habitats  Directive 
(92/43/EEC)  are  the  cornerstone  of  the  EU’s  legal  framework  for  the  conservation  and 
restoration of natural habitats and species of wild fauna and flora. Additionally, the EU 
biodiversity strategy to 202019 aims to halt the loss of biodiversity and the degradation of 
ecosystem services by supporting the EU Nature Directives’ full implementation and by 

27   https://ec.europa.eu/environment/action-programme/. 

9 

 
 
                                                      
increasing  the  contribution  of  agriculture  and  forestry  to  maintaining  and  increasing 
biodiversity. 

The  Water  Framework  Directive  (2000/60/EC)  is  the  most  comprehensive  and 
overarching instrument of EU water policy. It aims to protect all surface and groundwater 
bodies,  including  transitional  and  coastal  waters,  and  addresses  all  pressures  (including 
agriculture).  Its  aim  is  to  achieve  overall  good  ecological  status  (or  its  potential)  and 
good  chemical  status  for  all  surface  water  bodies,  and  good  chemical  and  good 
quantitative status for all groundwater bodies by 2015, or by justified extension to 202728. 
Preventing deterioration is also a key aim of the Directive.  

Other  directives  with  relevance  for  agriculture  that  affect  mainly  water  quality  are  the 
Nitrates  Directive 
the  Sustainable  Use  of  Pesticides  Directive 
(2009/128/EC), the EU Drinking Water Directive (98/83/EC), the Groundwater Directive 
2006/118/EC),  the  Environmental  Quality  Standards  Directive  (2008/105/EC)  and  the 
EU Floods Directive (2007/60/EC) for water quantity29. 

(91/676/EC), 

There is no specific EU legal framework for soil protection. It is addressed through the 
soil  thematic  strategy30  but  in  a  non-binding  way.  The  soil  thematic  strategy  aims  to 
protect  and  sustainably  use  soils  by  preventing  further  soil  degradation,  preserving  its 
functions  and  restoring  degraded  soils.  The  soil  thematic  strategy  will  be  updated  in 
2021.  Other  pieces  of  EU  legislation  setting  requirements  relevant  for  soil  include  the 
Land  Use,  Land  Use  Change  and  Forestry  (LULUCF)  Regulation  (EU)  2018/841,  the 
Sewage  Sludge  Directive  (86/278/EEC)  and  regulations  on  fertilisers31,  mercury32  and 
plant protection products33. 

Figure  2  presents  the  intervention  logic  of  the  relevant  CAP  measures  addressing  the 
impact of the CAP on natural resources. The measures are described in Heading 3, along 
with the state of play for their implementation. 

28   For  surface  waters  to  be  considered  ‘good’,  the  water  body  must  have  good  ecological  and  good 
chemical status. For groundwater bodies to be considered ‘good’, they  must  have good  chemical and 
good quantitative status. Explained in Figure 2 in the Water Fitness Check - SWD(2019)439. 

29   A comprehensive evaluation of most of these directives was performed in the fitness check of the water 

policies. See Water Fitness Check - SWD(2019)439.  

30   https://ec.europa.eu/environment/soil/three_en.htm. 
31   Regulation  (EC)  No  2003/2003  of  the  European  Parliament  and  of  the  Council  of  13  October  2003 

relating to fertilisers, OJ L 304, 21.11.2003, p. 1–194.  
Regulation (EU) 2019/1009 of the European Parliament and of the Council of 5 June 2019 laying down 
rules on the making available on the market of EU fertilising products and amending Regulations (EC) 
No  1069/2009  and  (EC)  No  1107/2009  and  repealing  Regulation  (EC)  No  2003/2003,  OJ  L  170, 
25.6.2019, p. 1–114. 

32   Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury, 

and repealing Regulation (EC) No 1102/2008, OJ L 137, 24.5.2017, p. 1–21. 

33   Regulation  (EC)  No  1107/2009  of  the  European  Parliament  and  of  the  Council  of  21  October  2009 
concerning  the  placing  of  plant  protection  products  on  the  market  and  repealing  Council  Directives 
79/117/EEC and 91/414/EEC, OJ L 309, 24.11.2009, p. 1–50. 

10 

 
 
 
                                                      
2.2.  Baseline and points of comparison  

The  Commission  legal  proposals  for  the  2013  CAP  reform  were  accompanied  by  an 
impact  assessment34,  which  described  the  situation  preceding  the  reform  and  included 
medium-term projections comparing no policy change (status quo / baseline) with policy 
alternatives. However, the medium-term projections are insufficient as a baseline for the 
purposes of this evaluation, as they do not correspond to the final outcome of the reform 
after negotiations with the European Parliament and Council.  

As there were no other objective and quantitative projections that could have been used 
as  a  baseline,  the  points  of  comparison  are  based  on  the  situation  before  the 
implementation of the 2014-2020 CAP, using the most recent data up to 2013, presented 
in Annex 5: Benchmark: the situation prior to the 2014-2020 CAP35. 

A further proxy for the performance of the CAP are the fulfilment of target indicators set 
for  relevant  focus  areas  of  rural  development  programmes  (presented  in  chapter  5). 

34   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52011SC1153. 
35   On  the  basis  of  available  data  on  relevant  CAP  indicators  from  the  online  agri-food  data  portal 
https://agridata.ec.europa.eu/extensions/DashboardIndicators/DataExplorer.html?select=EU28_FLAG,1 
Details  and  explanations  are  available  via  https://ec.europa.eu/info/sites/info/files/food-farming-
fisheries/farming/documents/cap-context-indicators-table_2014_en.pdf. 

11 

 
 
                                                      
Figure 2. Illustration of the intervention logic of the CAP measures related to natural resources 

Source: Directorate-General for Agriculture and Rural Development 

12 

 
 
 
 
3.  IMPLEMENTATION / STATE OF PLAY 

3.1.  Description of the current situation  

In 2019, 151 million hectares (84%) of all EU agricultural land were supported under the 
direct  payment  scheme  and  therefore  subject  to  the  requirements  for  compliance  with 
SMRs  and  the  relevant  practices  that  Member  States  have  established  under  GAECs36. 
Also in 2019, 142.3 million hectares (80%) of agricultural land were declared by farmers 
applying  at  least  one  greening  obligation,  26.7 million hectares  (15%)  were  supported 
under payment for agri-environment-climate commitments and 9.4 million hectares (5%) 
were under organic farming37. 

3.1.1.  Good agricultural and environmental conditions (GAECs) 
Member  States  have  translated  the  core  obligations  of  the  GAECs  in  different  ways, 
fitting their own circumstances.  

GAECs directly addressing water  

Under  GAEC 1  (buffer  strips),  all  Member  States  set  a  requirement  for  establishing 
buffer  strips  along  watercourses/waterbodies  with  no  application  of  fertilisers.  The 
minimum width spanned from less than 1 meter to more than 20 meters, with the strong 
majority of Member States setting buffer strips with a width ranging from 1 to 5 meters38. 
Member States differed in how they defined watercourse/water body where buffer strips 
are  required,  from  more  generic  to  specific  definitions  and  lists.  Flanders-Belgium, 
Croatia, Czechia, France and Spain also supplemented the basic requirement with a ban 
on  the  use  of  plant  protection  products  on  buffer  strips,  and  Austria,  Greece,  Italy  and 
Portugal banned tillage and/or cultivation.  

GAEC 2 (irrigation)  links CAP  payments  and the procedure defined by  Member States 
for  obtaining  an  authorisation/permit  to  use  water  for  irrigation.  The  procedure  (and 
therefore GAEC 2) is not applicable in Ireland and Luxembourg39. 

Under GAEC 3 (groundwater), which is applied in all Member States, CAP payments are 
linked  to  the  provisions  on  the  direct/indirect  discharge  of  the  listed  dangerous 
substances into groundwater. 

GAECs targeting soil and soil organic matter 

Under GAEC 4 (soil  cover), all Member States require minimum  soil cover. There is  a 
particular  focus  on  areas  with  a  high  risk  of  erosion,  and  there  are  time-specific  rules. 
Member  States  have  differed  in  the  way  they  identify  land  under  the  obligation:  the 
majority used only  a  general  specification (agricultural  area,  grasslands,  parcels),  while 
Cyprus,  Czechia,  Greece,  Latvia,  Malta  and  Poland  specified  arable  land  and  France, 
Germany and Spain fallow land. The approach for soil cover also differed. Only Belgium 
(Flanders  and  Wallonia)  and  Czechia  required  crop  residues/stubble.  and  only  Austria, 
Cyprus, Denmark, Estonia, Finland, Germany, Lithuania, Luxembourg, the Netherlands, 

36   CMEF indicator OIH_01_1a Cross-compliance. 
37   CMEF indicator OID_05 Greening, OIR_06_1.1 AECM and OIR_06_1.2 organic farming. 
38   Austria,  Flanders  (Belgium),  Bulgaria,  Cyprus,  Estonia,  Latvia,  Poland,  Portugal  and  Slovenia  set 

buffer strips exceeding 5 meters. 

39   In  Ireland  and  Luxembourg  it  is  not  applicable  as  no  irrigation  and  thus  no  water  authorisation 

procedures exist. 

13 

 
 
                                                      
Portugal,  Spain  and  Sweden  required  permanent  grassland/grass/green  cover.  On  the 
other  hand,  Croatia,  France,  Greece,  Hungary,  Ireland,  Italy,  Latvia,  Malta,  Romania, 
Poland, Slovakia and Slovenia allowed farmers to choose their soil cover from one of the 
two options mentioned. Germany and France set additional rules prohibiting bare fallow 
or restricting the use of plant protection products and fertilisers. 

Under  GAEC 5  (minimum  land  management  reflecting  site  specific  conditions  to  limit 
erosion), the main measures set by Member States tackled land with high slopes usually 
defined  as  more  than  a  10%  slope.  The  majority  of  Member  States  have  cultivation 
requirements  (transversal  to  the  contour  of  the  slope  and  minimal  tillage).  However, 
Wallonia (Belgium), Czechia, Hungary, Lithuania, Portugal and Slovakia limit crops to 
be planted (crops with small canopy, e.g. potato), and Flanders (Belgium), Denmark and 
France ban ploughing during a certain period (generally winter).  

All  Member  States  implement  the  main  measure  of  the  ban  on  stubble  burning  under 
GAEC 6  (maintenance  of  soil  organic  matter).  In  order  to  improve  the  soil  carbon 
content,  a  few  Member  States  go  beyond  this  core  requirement  by  requiring  (i)  a  soil 
analysis with possible corrective actions (Luxembourg), (ii) soil coverage with nitrogen-
fixing crops (Czech Republic), (iii) the incorporation of crop residues (Cyprus), (iv) crop 
rotation (Slovenia;  Malta)  and (v) a  ban on  cultivation  in  species-rich and semi-natural 
habitats. 

GAECs targeting biodiversity  

GAEC 7  (landscape)  targets  the  retention  of  landscape  features,  and  includes  a  ban  on 
cutting  woody  landscape  features  and  measures  for  preventing  the  introduction  and 
spread  of  invasive  alien  plants.  In  terms  of  retention  of  landscape  features,  Member 
States differed as to the type and number of features subject to protection. The majority 
(25)  of  Member  States  selected  mainly  the  nine  landscape  features  suggested  in  the 
legislation  (hedges,  ponds,  ditches,  trees  in  line,  group  of  trees,  isolated  trees,  field 
margins,  terraces  and traditional stonewalls)  that are  considered as  essential to  preserve 
biodiversity.  However,  Latvia  and  Austria  selected  only  elements  that  are  not  on  the 
suggested list such as protected trees and natural monuments, and the Netherlands did not 
select any element for protection. 

3.1.2.  Statutory management requirements (SMRs)  
Under SMR 1 (nitrates), Member States are required to establish a programme of actions 
which  is  compulsory  in  nitrate  vulnerable  zones  and  whose  items  are  verified  under 
cross-compliance. The measures that Member States must implement in  these areas are 
those already included in the Codes of Good Agricultural Practice set out in the Nitrates 
Directive and other measures such as limiting fertilizer application (mineral and organic), 
taking into account crop needs, all nitrogen inputs and soil nitrogen supply and setting a 
maximum amount of livestock manure that can be applied. Member States are therefore 
required to identify specific vulnerable zones and set up and operate action programmes. 

SMR 2 (wild birds) and SMR 3 (habitats) target biodiversity, as Member States are under 
the  obligation  to  protect  certain  landscape  features  under  the  Birds  and  Habitats 
Directive. As such, these SMRs  help to enforce  farm-level compliance with national or 
regional legal restrictions that protect certain habitats and species covered by the Nature 
Directives. 

SMR 10  (plant  protection  products)  targets  water  and  soil  protection,  as  it  requires 
farmers  to  apply  the  principles  of  good  plant  protection  practices  (set  out  under 

14 

 
 
Article 55 of Regulation 1107/200940) and comply with market authorisations on the use 
of plant protection products. 

3.1.3.  Greening 
The greening measures target in particular soil quality (crop diversification), biodiversity 
(ecological focus area (EFA) and environmentally sensitive permanent grassland) and the 
preservation of carbon stocks in agricultural soils (permanent grassland, environmentally 
sensitive permanent  grassland). No specific measure directly addresses water quality or 
quantity. However, specifications for some of the EFA elements consider the impact on 
and/or  contribute  to  improved  water  management,  i.e.  buffer  strips,  catch  crops  and 
nitrogen-fixing  crops,  ban  on  the  use  of  pesticides  on  fallow  land  and  productive  EFA 
areas. Further impacts are also linked to preservation of permanent grasslands or positive 
effects stemming from greater crop diversity. 

The  greening  rules  do  not  apply  to  farmers  who  opted  for  the  small  farmer’s  scheme 
(2.1% of UAA in 2019), for administrative and proportionality reasons. Organic farmers 
(7.9% of UAA in 2019) automatically receive a greening payment for their farm, as they 
are considered to provide environmental benefits by the nature of their work41.  

Crop diversification 

In  2019,  74%  of  the  EU  arable  land  fell  under  the  crop  diversification  obligation 
(77.7 million hectares).  Of  the  farms  applying  the  crop  diversification,  87%  of  arable 
land was under the obligation to have at least three crops and the remaining 13% under 
the obligation to have at least two crops, though the figures differ at Member State level 
depending  on  the  average  size  of  the  arable  land  of  farms.  While  6  Member  States 
(Bulgaria,  Estonia,  France,  Latvia,  Slovakia,  United  Kingdom)  had  95%  or  more  of 
arable  land  under  three  crop  obligation,  3  Member  States  had  around  half  (Slovenia, 
Finland)  or  more  (Greece)  of  their  arable  land  under  two  crops.  In  the  case  of  Malta, 
farms had only a two crop rule. 

Permanent grassland 

In  2019,  51.7 million hectares  of  permanent  grassland  were  declared  under  the  direct 
payment scheme and the area of permanent grassland under the greening ratio obligation 
amounted  to  46.7 million hectares.  The  figures  under  the  greening  ratio  do  not  include 
the exempted areas of the small farmer scheme and organic producers. 

The overall share of permanent grassland in agricultural areas under greening was 31.6% 
in  2019,  ranging  from  2.4%  in  Cyprus  (2019)  to  89.9%  in  Ireland  (2018).  The 
reconversion mechanism was activated four times in two Member States (Cyprus: 2015 
and 2016, Estonia:  2016 and 2018) to  reverse a  more than 5% drop in  the annual  ratio 
against the 2015 reference ratio.  

Environmentally sensitive permanent grassland (ESPG) 

ESPG  designation  entitles  stricter  protection  of  grassland  parcels  in  order  to  meet  the 
objectives  under  the  Natura  2000  Directives.  In  2019,  of  16.6 million hectares  of 

40   Regulation  (EC)  No  1107/2009  of  the  European  Parliament  and  of  the  Council  of  21  October  2009 
concerning  the  placing  of  plant  protection  products  on  the  market  and  repealing  Council  Directives 
79/117/EEC and 91/414/EEC, OJ L 309, 24.11.2009, p. 1–50. 

41   On  the  basis  of  CMEF  indicators  OID_13  Small  farmers'  scheme  (OID_13_2)  and  C.19  Agricultural 

area under organic farming (CTX_SEC_19_2). 

15 

 
 
                                                      
permanent grassland in Natura 2000 areas, 9.3 million hectares (56%) were designated as 
ESPG and 5.7 million hectares (34%) declared by farmers. This translates into 17% of all 
permanent  grassland in  EU designated as ESPG (ranging from 0.2% in  Portugal to just 
over 57% in Cyprus). 

These  figures  reflect  the  differences  in  the  delineation/selection  of  Natura 2000  areas 
when  implementing  the  underlying  Nature  and  Birds  Directives  and  the  differences  in 
Member  States’  decisions  to  designate  permanent  grassland  within  the  Natura  areas. 
Eight Member States (Bulgaria, Czechia, Greece, Italy, Hungary, Netherlands, Slovakia, 
Finland,  Sweden)  designated  all  permanent  grasslands  within  Natura 2000  as  ESPG, 
while others designated only a proportion. The lowest proportion of permanent grassland 
in  Natura 2000  areas  designated  as  ESPG  in  2019  was  in  Portugal  (1.3%)  and  Ireland 
(4.0%). ESPG declared by farmers ranged from 0.1% of permanent grassland in Natura 
2000 in Portugal and 2% in Austria to 100% in Greece and in Sweden. 

Four  Member  States  (Belgium,  Czechia,  Italy,  Latvia)  also  designate  permanent 
grassland outside Natura 2000 areas as ESPG, adding protection to an additional 0.6% of 
all EU permanent grasslands.  

Ecological focus area (EFA) obligation 

In  2019,  69%  of  EU  arable  land  fell  under  the  EFA  obligation  (72.4 million hectares). 
The  selection  of  EFA  areas  and  features  differed  across  Member  States,  with  some 
opening the whole range of EFA types and others only a narrow range. A major change 
from 2018 onwards came from the amendments to the Omnibus Regulation42 where three 
EFA  types  were  added  and  weighting  factors  increased  for  nitrogen-fixing  crops  and 
short rotation coppice. A major change also came from the amendments to the delegated 
legislation that restructured some landscape features’ EFA types and banned the use of 
plant  protection  products  on  fallow  land  and  productive  EFA  types.  In  2019, 
9.5 million hectares  were  declared  EFA  areas,  representing  13.7%  of  arable  land  under 
obligation. 

Table 2 Areas under EFA before applying weighting factors (to nearest 000)* 

Land lying 
fallow and 
land lying 
fallow 
melliferous  

Landscape 
features, 
terraces  

Buffer 
strips, field 
margins, 
strips along 
forest edges  

Afforested  areas, 
agroforestry, 
Short 
coppice, 
Miscanthus, 
Silphium  

rotation 

Catch crops  

Nitrogen- 
fixing crops  

Total 

2015 
Share in 
total EFA 
2019 
Share in 
total EFA 

2 508 000 

160 000 

96 000 

74 000 

3 952 000 

3 774 000 

10 561 000 

24% 

1.5% 

1% 

1% 

37% 

36% 

100% 

1 851 000 

182 000 

96 000 

38 000 

5 171 000 

2 208 000 

9 542 000 

19% 

1.9% 

1% 

0.4% 

54% 

23% 

100% 

*Structure further to changes introduced by Omnibus Regulation and the 2017 delegated legislation 

In terms of uptake by farmers, the most frequently declared EFA types were those linked 
to productive or potentially productive EFAs: nitrogen-fixing crops, catch crops and land 
lying fallow. In 2019 catch crops areas represented just over half and the nitrogen-fixing 
crops areas  just below a quarter of all. The share of fallow land was a fifth  of all EFA 
areas. The EFA types that are most valuable for the environment (i.e. landscape features) 
account for less than 2% of the area under EFA, whereas the EFA type that provides the 

42 Regulation (EU) No 2017/2393; O.J. L 350, 29.12.2017, p. 15-49. 

16 

 
 
 
                                                      
lowest  benefits  for  biodiversity,  nitrogen-fixing  crops,  is  one  of  the  types  that  is 
frequently chosen (representing 23% of the area). 

Analysis  of  the  EFA  composition  in  Member  State  in  2020  (Figure  3)  revealed  the 
following patterns: 

 

 

5 Member States had at least 50% of fallow land, of which 2 had more than 75%;  

10 Member States had at least 50% of catch crops of which 4 had more than 75%;  

  Altogether,  15  Member  States  had  more  than  80%  of  EFAs  dedicated  to  nitrogen-

fixing crops or catch crops;   

 

In 6 Member States, landscape features, buffer and other strips and forestry-related 
areas accounted for more than 3% of all EFAs. 

Figure 3 Main types of EFA area in 2019, before applying the weighting factors 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Nitrogen fixing crops

Catch crops

Afforested areas, agroforestry, Short rotation coppice, Miscanthus, Silphium

Buffer strips, field margins, strips along forest edges

Landscape features, terraces

Land lying fallow and land lying fallow melliferous

Source: Directorate-General for Agriculture and Rural Development, based on Member States´ notifications  

After  applying the  weighting factors, nitrogen-fixing crops  and catch  crops account for 
above  half  of  the  total  weighted  EFAs  in  2019,  representing  6-7%  of  the  arable  land 
under the obligation and contributing to overshooting the required 5% at farm level.  

Table 3 Areas under EFA after applying weighting factors (to nearest 000)* 

Land lying 
fallow and 
land lying 
fallow 
melliferous  

Landscape 
features, 
terraces  

2 508 000 

323 000 

Buffer 
strips, field 
margins, 
strips 
along 
forest 
edges  
128 000 

Afforested 
areas, 
agroforestry, 
Short 
coppice, 
Miscanthus, 
Silphium  

rotation 

Catch crops   Nitrogen  

Total 

58 000 

1 186 000 

2 642 000 

6 842 000 

37% 

4.7% 

2% 

1% 

17% 

39% 

100% 

1 864 000 

425 000 

212 000 

29 000 

1 552 000 

2 208 000 

6 287 000 

30% 

6.8% 

3% 

0.5% 

25% 

35% 

100% 

2015 
Share in 
total 
EFA 
2019 
Share in 
total 
EFA 

*Structure further to changes introduced by the Omnibus Regulation and the 2017 delegated legislation 
Source: Directorate-General for Agriculture and Rural Development 

17 

 
 
 
 
Table 4 Weighted EFA areas as a share of arable land under the EFA obligation (to nearest 
000)* 

Land lying 
fallow and 
land lying 
fallow 
melliferous  

Landscape 
features, 
terraces  

Buffer 
strips, field 
margins, 
strips along 
forest edges  

Afforested 
areas, 
agroforestry, 
Short  rotation 
coppice, 
Miscanthus, 
Silphium  

Catch crops  

Nitrogen 
fixing crops  

2015 

3.3% 

0.4% 

0.2% 

0.1% 

1.6% 

3.5% 

2019 

2.6% 

0.3% 
3.0% 
*Structure further to changes introduced by Omnibus Regulation and the 2017 delegated legislation 
Source: Directorate-General for Agriculture and Rural Development 

0.04% 

0.6% 

2.1% 

Total 

9.1% 

8.7% 

3.1.4.  Rural development measures (supported by EAFRD) 
The  rural  development  policy  of  the  CAP  is  implemented  over  a  seven-year  period 
through  rural  development  programmes  (RDP)  designed  by  national  or  regional 
managing  authorities.  A  total  of  118  RDPs  are  implemented  in  the  28  Member  States, 
with  EUR 99.6 billion  in  funding  over  the  2014-2020  period.  After  co-funding  by 
national,  regional  and  private  resources  is  added,  the  rural  development  policy  of  the 
CAP has a total of EUR 161 billion in funding.  

Table 5: Measures programmed (total public) under priorities 4 and 5  

Measures 

Priority 4 

Priority 5 

EUR 
million 

% 

EUR 
million 

% 

Share of the 
measure 
programmed 
under 

priorities       
4 and 543 

         1 398  

1% 
           363  
           305   0.4% 
3% 
         2 119  
0% 

M01 Knowledge transfer/information 
M02 Advisory services 
M04 Investments in physical assets 
M06 Farm business and development 
M07 Basic services and village 
renewal 
M08 Forest investments 
M10 Agri-environment-climate 
M11 Organic farming 
M12 Natura 2000 and WFD 
M13 Areas facing natural constraints 
M15 Forest-environment-climate 
M16 Cooperation 
Total 
Source: Directorate-General for Agriculture and Rural Development  

4% 
         3 055  
35% 
       24 021  
17% 
       11 549  
1% 
           808  
       24 226  
35% 
           286   0.4% 
1% 
           427  
       68 558   100% 

2% 

         125  
           62  
      4 767  
         146  

1% 
0.6% 
50% 
2% 

         258  

3% 

      2 487  
      1 193  
         131  
             7  
         221  
             3  
         208  
      9 608  

26% 
12% 
1% 
0% 
2% 
0% 
2% 
100% 

34% 
46% 
20% 
2% 

16% 
92% 
100% 
100% 
100% 
97% 
100% 
25% 
52% 

At  EU  level  in  the  period  2014-2020,  Member  States  allocated  46%  (almost 
69 billion euros)  of  their  rural  development  budgets  to  restoring,  preserving  and 
enhancing  ecosystems  (priority  4)  and  over  5%  (9 billion euros)  to  a  resource-efficient, 
climate-resilient economy (priority 5). This amounts to a total of almost 77 billion euros, 

43   This column refers to the % of the budget allocated to CAP measures and instruments that were under 
priorities  4  (preserving  and  enhancing  ecosystems)  and  5  (a  resource-efficient,  climate-resilient 
economy). 

18 

 
 
 
 
  
                                                      
i.e.  51%  of  all  rural  development  funding  spent  by  Member  States44.  At  the  end  of 
September 2020, the EU-28 had executed 76% of the planned public expenditure under 
priority 4 and 46% under priority 5.  

Under  priority  4,  support  for  ANC  (M13)  accounted  for  35%  of  all  spending,  with 
AECMs  (M10)  a  further  35%,  organic  farming  17%  and  forestry  measures  5%.  Under 
priority 5, the main measures are physical investments (M4) with 50%, forestry measures 
(M8) with 26% and AECM with 12% of total allocations45.  

This  spending  on  AECM  and  organic  farming  has  resulted  in  covering  more  than  40 
million  hectares  for  AECM  and  organic  farming  (23%  of  UAA),  with  a  number  of 
different practices implemented to address the environmental impact of the CAP.  

Table 6. Example of practices supported under RDP addressing natural resources 

Conservation of grassland 

Conservation  of 
elements 

landscape 

Crop 
rotation 

diversification 

& 

Organic farming 

Maximum livestock density 

Other  limitations  of  pesticide 
use 

Intermediate 
crops/catch crops 

crop/cover 

Buffer strips along superficial 
water bodies 

Erosion 
permanent crops 

protection 

on 

Source: Directorate-General for Agriculture and Rural Development 

3.1.5.  Other measures  
Knowledge exchange plays a key role in helping farmers and rural communities meet the 
challenges  of  natural  resources,  mainly  through  knowledge  transfer  and  information 
actions (M1), advisory services (M2) and cooperation (M16).  

At  present,  all  countries  in  the  European  Union  have  to  have  a  farm  advisory  system 
(FAS). The FAS helps farmers to better understand the EU rules for environment, public 
and animal health, animal welfare and the good agricultural and environmental condition 
(GAEC). The FAS itself is not an instrument (in practice it may be a telephone helpdesk 
or a website with important information) and does not provide funding. Several Member 
States and regions provide support from EAFRD (M2-Advisory services) to facilitate the 
implementation  of  the  FAS  (Belgium-  Flanders,  Estonia,  Italy,  Lithuania,  Malta, 
Portugal, Slovakia and UK-Scotland). 

The  European  Innovation  Partnership  for  Agricultural  Productivity  and  Sustainability 
(EIP-AGRI)  was  set  up  to  encourage  innovation  in  agriculture  and  rural  communities. 
Thanks  to  innovative  solutions  created  through  the  interaction  of  a  mix  of  relevant 
competent actors, including the end-users of the outcomes, the EIP speeds up innovation. 
Of the more than 3 000  projects  planned for 2014-2020,  more than  2 000  were  already 
finished or running at the end of 2021, and extra calls are planned.  

44   For 

a 

comprehensive 

and 
https://enrd.ec.europa.eu/sites/enrd/files/priority-4-summary.pdf. 
and 
https://enrd.ec.europa.eu/sites/enrd/files/priority-5-summary.pdf. 

comprehensive 

overview 

overview 

facts 

facts 

key 

key 

of 

of 

a 

45   For 

figures 

on 

priority 

4, 

visit 

figures 

on 

priority 

5, 

visit 

19 

 
 
                                                      
The operational group projects of the EIP follow the interactive innovation model46 and 
65%  of  them  work  on  environment-climate  issues,  of  which  42%  on  biodiversity,  soil 
and  water  and  another  10%  on  landscape/landscape  management.  Around  the  (farmer) 
partners in  the operational  group, a circle of up to 100 farmers are co-learning peer-to-
peer by attending the project’s activities.  

Some  Member  States  even  started  using  operational  groups  as  a  test  bed  for  preparing 
agri-environmental  measures  with  great  success.  It  works  as  an  early  promotion  for  a 
ready  to  use  measure  and  -  more  importantly  -  creates  co-ownership  and  trust  in  the 
measure for the future beneficiaries.  

The  inclusion  of  advisors  in  operational  group  projects  strengthens  the  Agricultural 
Knowledge and Innovation System (AKIS) by helping set up and implement innovative 
projects.  The  inclusion  and  environmental  training  of  impartial  and  trusted  advisors 
within the AKIS should have an important impact on farmers’ environmental behaviour. 

3.1.6.  Reporting on infringements/problems  
To  enforce  cross-compliance,  beneficiaries  who  do  not  comply  fully  with  requirements 
and standards of cross-compliance have to pay a penalty, which is applied as percentages 
to their overall CAP payments  

Farmers  who  do  not  respect  greening  rules  receive  less  money.  Such  reductions  reflect 
the number of hectares identified as non-compliant, taking into account the nature of the 
greening  requirement.  Since  2017,  national  governments  can  impose  administrative 
penalties on top of the reduction in greening payments. Administrative penalties have to 
be proportionate, depending on the severity and scope of the non-compliance. Details of 
the control/sanctions system is provided in Annex 6: Information complementing chapter 
3. 

On  the  basis  of  2019  data,  infringement  rates  with  no  sanction  for  cross-compliance 
remained marginal (0-1%) in the overwhelming majority of Member States/regions. In a 
very few cases, a more considerable rate was found:  

  SMR 1  (nitrates):  11%  in  the  UK,  9%  in  Sachsen-Anhalt  (Germany),  8%  in 

Estonia; 

  SMR 2  (wild  birds):  13%  in  La  Rioja  (Spain),  10%  Asturias  (Spain),  9%  in 

Navarra (Spain); 

  GAEC 2 (irrigation): 18% in Wallonia (Belgium); 

  GAEC 3 (groundwater): 4 to 17% in various regions of Italy; 

  GAEC 4 (soil cover): 6-14% in select regions of Spain; 

  GAEC 5 (soil erosion): 18% in Flanders (Belgium). 

The error rate for direct payments was very low during the 2014-2020 period, under 2% 
every year.  

46   Collaboration  between  various  actors  to  make  best  use  of  complementary  types  of  knowledge 
(scientific, practical, organisational, etc.) in  view of  co-creation and  the  quick spreading  of solutions/ 
opportunities  which  are  ready  to  be  implemented  in  practice.  This  innovation  model  creates  co-
ownership  by  farmers,  and  thus  results  in  easier  uptake  and  broader  dissemination  than  any  other 
innovation project. 

20 

 
 
                                                      
The adjusted error rate for the total relevant expenditure for all RDP measures was 2.92% 
for  the  2014-2020  period,  with  approximately  half  of  all  paying  agencies  (71  in  total) 
producing  an  error  rate  above  2%.  In  2019,  measures  relevant  for  the  sustainable 
management  of  natural  resources,  notably  M10  (AECM),  M11  (organic  farming),  M12 
(Natura 2000 and Water Framework Directive) and M13 (ANC) showed a very low error 
rate  of  2.55%  for  the  EU  as  a  whole.  However,  in  some  cases  a  more  considerable 
(commitments) error rate was observed: 

  M10 (AECM): above 5% in 15 regions (of Belgium, Bulgaria, Germany, Spain, 

Greece, Croatia, the Netherlands and Slovakia); 

  M11 (Organic farming): above 5% in 5 regions (of Bulgaria, Germany, Spain and 

Slovakia); 

  M12 (Natura 2000 and Water Framework Directive): above 5% in 2 regions (of 

Spain and Luxembourg); 

  M13 (ANC): above 5% in 1 region (of Italy). 

4.  METHOD 

The  evaluation  is  primarily  based  on  the  external  evaluation  support  studies  on 
biodiversity,  soil  and  water  and  the  responses  to  the  corresponding  public 
consultation.  It  also  draws  on  the  evaluations  on  payments  for  agricultural  practices 
beneficial  for  the  climate  and  the  environment,  on  forestry  measures  under  rural 
development  and  the  impact  of  the  CAP  on  climate  change  and  greenhouse  gas 
emissions.  The  evaluation  is  also  informed  by  additional  analysis  and  complementary 
data  from  various  sources,  including  publications  by  the  European  Parliament  and  the 
European Court of Auditors. 

4.1.  Short description of methodology 

The methodological approach combines theoretical and empirical analysis and includes 
a variety of quantitative and qualitative methods to deal with the complexity and the wide 
range of topics under the evaluation.  

The  starting  point  of  the  external  studies  on  biodiversity,  soil  and  water  was  the 
development of the intervention logic for the CAP instruments and measures to identify 
their potential direct and indirect impacts on the three themes.  

The  evaluation  tools  and  methods  included,  but  were  not  limited  to:  documentary 
research, literature reviews, statistical data analysis, case studies surveys and interviews 
with stakeholders as part of the three studies, public consultation, etc. The collected data 
was analysed through both quantitative and qualitative methods.  

The databases utilised in the evaluation study included: annual implementation reports 
on the EAFRD (AIRs), the Clearance Audit Trail System (CATS), common monitoring 
and evaluation framework indicators (CMEF), the European Soil Data Centre (ESDAC), 
Eurostat  agri-environmental  indicators  (AEI),  the  Farm  Accountancy  Data  Network 
(FADN), the Farm Structure Survey (FSS), the Land Use and Cover Area frame Survey 
(LUCAS),  the Water  Information System  for Europe (WISE),  etc. The indicators used 
included among others, context, output, result and target indicators from  the CMEF for 
biodiversity,  soil,  water  and  the  environment  in  general,  the  Streamlining  European 
the  Sustainable  Forest 
(SEBI 
Biodiversity 
Managements (SFM), WISE, etc..  

for  biodiversity), 

indicators 

from 

21 

 
 
The case studies  selected for the three studies  provide  insight  into the implementation 
and effect of the instruments and measures, covering as much as possible the variety of 
contexts across the EU. Case studies have been selected in such a way that the relevant 
water,  soil  and  biodiversity-related  issues  can  be  covered  efficiently  and  clearly, 
representing the diversity of scenarios of the EU. The case studies included, but were not 
limited  to:  stakeholder  consultations  through  semi-structured  interviews,  documentary 
research including literature reviews, statistical  data collection at  national, regional  and 
local  level,  and  complementary  interviews.  The  selection  criteria  and  resulting  case 
studies are presented in Annex 3: Methods and analytical models. 

A  public  consultation  was  conducted  on  the  European  Commission’s  EU  Survey 
platform between 9 July and 22 October 2020, collecting 183 responses from 25 Member 
States47 and Israel. 

4.2.  Limitations and robustness of findings 

The  evaluation  is  subject  to  a  number  of  limitations  that  impact  the  analysis  and  its 
robustness. 

Despite  a  careful  selection  of  case  studies  to  reflect  the  variety  of  situations  across  the 
EU, the case studies do not provide a fully representative sample. This can be explained 
by the large territorial differences in terms of natural resources and the high variability of 
Member State implementation choices with regard to the CAP instruments and measures 
addressing natural resources,.  

Processes involving natural resources are long-term phenomena whose trends cannot be 
observed  on  the  short  timescale  of  the  CAP  programming  period,  which  has  a  limited 
availability of relevant data. Furthermore, a forensic assessment of the CAP’s impact on 
biodiversity,  soil  and  water  is  challenging  when  other  factors  are  acting  in  parallel, 
including the increase in population and urban sprawl, economic development, pollution, 
invasive species and climate change. 

The  effects  of  other  EU  and/or  national  policies  and  the  indirect  effects  of  other  CAP 
instruments  and  measures  not  designed  and  implemented  to  address  the  sustainable 
management  of  natural  resources  are  not  sufficiently  taken  into  consideration,  if  at  all. 
On a different level, the selection of crops and crop varieties are affected by demand and 
the variability of climatic conditions, factors not considered in this analysis. 

Data  is  not  always  available  to  quantify  the  effects  of  CAP  measures  and  instruments, 
due to discrepancies in the time period or the geographical scale to be considered. This 
seriously  affects  the  ability  to  establish  and  identify  the  net  impact  results  of  CAP 
policies and to establish true counterfactuals accurately for any period of time studied. 

Despite  the  extensive  monitoring  of  the  CAP  and  data  collection  from  EU  farms,  the 
available databases have limitations for assessing the quantitative effects of the CAP on 
natural resources at farm or at local level. 

Additionally, and given  that all the evaluation  studies on natural  resources use to  some 
extent the FADN database, several limitations arise from the use of this database.  

47   Including the UK, which was considered as a Member State for the purpose of the consultation. There 

were no contributions from Croatia, Malta and Lithuania. 

22 

 
 
                                                      
These limitations may affect the possibility to run  a complete statistical analysis and to 
monitor environmental impacts:  

  The sample varies over time to avoid a bias towards more performing farms. This 

limits the possibility to follow changes in farm management over time. 

  FADN  data  does  not  make  it  possible  to  distinguish  beneficiaries  of  each  rural 

development measure. 

  FADN includes a limited number of environmental indicators.  

 

In accordance with FADN data protection rules and to ensure representativeness, 
samples with less than 15 farms have not been analysed, limiting the analysis of 
very  targeted  groups  of  farms.  As  a  result  of  the  above,  in  the  analysis,  some 
types of farms and agricultural practices are over-represented. 

The  aggregated  output  data  under  restoring,  preserving  and  enhancing  ecosystems 
(priority  4)  for  rural  development  makes  it  impossible  to  record  detailed  budget  and 
operations  by  single  farming  practice.  Therefore  their  environmental  effects  cannot  be 
disentangled. 

Little  information  was  provided  regarding  the  impact  on  soil  productivity,  given  the 
unclear definition of ‘soil productivity’ that can relate to either soil fertility or yields. The 
concrete impact of CAP measures and instruments on soil fertility can be observed only 
in the long term. 

While the implementation reports of the Water Framework Directive contain information 
from Member States on the modification of the waterbodies and the main pressures, this 
information  is  only  available  for  large  areas  (corresponding  to  water  basins),  and 
therefore limits analysis of water use at lower (disaggregated) levels. 

Over the period of the evaluation studies, the methodological approaches were reviewed 
and  adapted  if  necessary  to  ensure  an  appropriate  analysis  of  those  data  which  were 
available.  Additionally,  where  possible,  information  has  been  triangulated  across 
multiple sources, and the partial nature of available information is acknowledged.  

Nevertheless,  by  extending  the  analytical  framework  with  complementary  sources,  the 
evaluation  provides  a  comprehensive  assessment  of  the  impact  of  relevant  CAP 
instruments  and  measures  on  addressing  sustainable  management  of  natural  resources, 
providing  useful  case  study  examples  on  good  practices  and  informed  qualitative 
analysis,  leading  to  useful  conclusions  and  lessons  learned  (including  the  need  for 
sufficient and timely indicators).   

5.  ANALYSIS  

5.1.  Effectiveness 

The assessment of how effective the CAP instruments and measures were in addressing 
water,  biodiversity  and  soil  objectives  is  based  on  the  evaluation  support  studies  and 
replies to the public consultation. Updated data, analysis and findings from other sources 
as referenced complemented this information.  

Implementation choices having a major impact on results  

The CAP provides Member States with flexibility in fine-tuning cross-compliance and in 
the type of measures they adopt. They also have flexibility with the budget allocated to 
these measures under pillar II. In broad terms, the implementation choices that Member 

23 

 
 
States made suggest that the environment was not their top priority. Instead, their choices 
have  primarily  been  driven  by  socio-economic,  financial  and  administrative  factors, 
which has limited the CAP’s potential to address the sustainable management of natural 
resources.  Member State choices  were also  driven by  their experience  of  implementing 
the CAP in the 2007-2013 period.  

As  for  the  instruments  and  measures  they  chose  to  implement  in  order  to  address  the 
sustainable management of natural resources,  they  needed a specific approach suited to 
local  conditions.  This  was  justifiable,  given  the  diverse  environmental  conditions  and 
challenges across Member States and regions.  

On the basis of Member States selected for case studies in  the study on biodiversity, it 
appears  that  at  a  strategic  level,  the  priorities  identified  by  Member  States  during  their 
strategic  planning  documents  for  biodiversity  (e.g.  prioritised  action  frameworks  and 
national  biodiversity  strategic  action  plans)  are  relatively  well  aligned  and  reflected  in 
their  rural  development  plans.  However,  when  implementing  the  CAP,  Member  States 
chose  instruments  and  measures  that  were  not  well  aligned  with  these  priorities.  They 
failed to make use of the full range of CAP measures that would have been suited to meet 
these priorities. In particular, the analysis of the local implementation choices in the case 
study  areas  in  the  study  on  soil  reveals  that  Member  States  and  managing  authorities 
made implementation choices that were unevenly aligned with soil threats at local level.  

In  Member  States’  decisions,  soil  quality  was  given  less  importance  than  other 
environmental  concerns  (i.e.  biodiversity  and  water  which  benefit  from  binding  EU 
objectives  and  dedicated  legislation  or  services).  This  was  due  to  the  absence  of  a 
specific  soil  directive  or  EU  soil  legislation,  and  the  lack  of  common  EU  definitions, 
targets and thresholds.  

Involving  water  authorities  in  the  design  process  of  the  RDPs,  notably  through  the  co-
funding of rural development measures, played a significant role in the implementation 
of measures supporting practices beneficial to the sustainable management of water. The 
existence  of  EU  legislation  on  water,  including  legally  binding  targets,  may  have 
contributed to this prioritisation.  

For  farmers,  the  choice  whether  to  engage  in  biodiversity,  water  and/or  soil  quality-
focused  measures  was  mostly  driven  (when  given  the  choice)  by  a  combination  of 
economic and financial factors and by a convenient (simple) policy design and degree of 
similarity  with  existing  land  management  practices.  All  evaluation  support  studies 
showed that, to a lesser extent, environmental awareness and market developments also 
played  a  role,  though  minor,  in  the  implementation  choices  that  farmers  made. 
Nevertheless,  with  farmers’  increased  awareness  of  environmental  issues,  the  studies 
have shown farmers adopting more environmental practices and measures.  

The lack of technical knowledge and advice (e.g. on alternative practices, relevant CAP 
support) appears as a key factor hindering the implementation of management practices 
addressing  soil  quality  (but  possibly  common  to  biodiversity  and  water  as  well).  As 
mentioned  by  the  farm  advisers  surveyed  in  the  case  studies,  the  environmental  and 
climate motivations were secondary reasons pushing farmers to implement the following 
RDP measures: investments (M4), organic farming (M11) and AECMs (M10).  

The interviews (from case studies in Germany, France and Austria) revealed that water-
related measures are (financially) less attractive for intensive farming systems, which are 
generally located in regions facing water problems. It also means that CAP measures that 

24 

 
 
could  help  to  address  water  problems  are  rarely  implemented  precisely  in  those  areas 
where they are most needed.  

The  public  consultation  conducted  for  the  evaluation  enquired  about  the  respondents’ 
perception  of  the  CAP’s  general  contribution  to  the  EU’s  environmental  objectives. 
Replies did not yield a clear and general assessment. A majority of respondents (business 
associations  and  companies  gave  the  highest  rates  of  approval;  public  authorities  were 
neutral;  NGOs,  researchers  and  EU  citizens  were  negative)  considered  that  the  CAP 
helped to achieve the EU’s environmental objectives ‘to a very large extent’, ‘to a large 
extent’  or  ‘to  some  extent’.  However,  the  perception  varies  across  the  different 
objectives. Depending on the topic, 14% to 32% of the respondents believe that the CAP 
contributes  ‘to  a  very  large  extent’  or  ‘to  a  large  extent’  to  environmental  objectives, 
whereas  36%  to  45%  believe  that  it  contributes  ‘to  a  very  small  extent’  or  ‘not  at  all’. 
Biodiversity  and  soil  received  the  highest  rate  of  positive  replies  (very  large  or  large 
extent) and climate adaptation and GHG emissions reduction the highest rate of negative 
replies (not at all).  

Environmental objectives and the CAP 

Figure 4 CAP contribution to environmental objectives of the EU 

5%

9%

35%

22%

23%

5%

Adapting to climate change (N=171)

8%

18%

27%

29%

12%

6%

Fostering carbon conservation and sequestration in agriculture
and forestry (N=164)

8%

13%

34%

20%

17%

8%

Reducing ammonia emissions from agriculture (N=164)

6%

16%

31%

21%

20%

6%

Reducing greenhouse gas emissions from agriculture (N=166)

6%

26%

8%

23%

28%

32%

27%

11%

1%

Restoring, preserving and enhancing biodiversity, habitats and
landscapes (N=168)

22%

15%

1%

Preventing soil erosion and improving soil management
(N=166)

7%

19%

33%

29%

7%

5%

Improving water quality (N=177)

2%

14%

36%

31%

9%

8%

Increasing efficiency in water use by agriculture (N=177)

To a very large extent

To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation14 

5.1.1.  Effectiveness of CAP instruments and measures contributing to the sustainable 

management of natural resources 

The  CAP  aims  to  provide  a  basic  and  extensive  ‘baseline  protection’,  with  84%  of  the 
total  EU  utilised  agriculture  area  (UAA)  subject  to  mandatory  cross-compliance,  with 
greening  obligations  providing  additional  environmental  protection  covering  80%  of 
UAA,  voluntary  commitments  under  pillar  II  adding  more  targeted  environmental 
provisions on 15% of UAA for AECM (M10) and 5% supporting organic farming (M11). 
The  area  subject  to  sustainable  management  commitments  has  increased  over  the 
evaluation period. 

25 

 
 
 
Agricultural  land  subject  to  cross-compliance  concerned  151 million hectares  in  201948. 
Agricultural land declared by farmers applying at least one greening obligation amounted 
to  142.3 million hectares  in  2019.  The  area  supported  under  payment  for  agri-
environment-climate commitments (M10) covered 26.7 million hectares in 2019, and the 
area 
to 
9.4 million hectares  in  201949  (while  the  total  public  expenditure  under  M11  doubled 
from EUR 938.8 million  in 2015 to over EUR 2 billion in 201950). The CAP support for 
conversion  and  maintenance  of  organic  farming  involved  14.3 million hectares  in  2019 
(+28% from 2015)51. 

supported  under  payment 

for  organic 

increased 

farming 

(M11) 

Figure  5  Utilised  agricultural  area  (UAA)  and  UAA  under  environmental  provisions 
(million ha) 

 200

 180

 160

 140

 120

 100

 80

 60

 40

 20

 -

2015

2016

2017

2018

2019

Total utilised agricultural area (UAA)

Number of hectares subject to cross-compliance (BPS+ SAPS)

Hectares of agricultural land declared by farmers applying at least one greening obligation

Physical area supported under payment for agri-environment-climate commitments (M10.1)

Physical area supported for  organic farming (M11)

Source:  CMEF  indicators  C.18  Agricultural  area  (CTX_SEC_18_1),  OIH_01_1a,  OID_05_3,  OIR_06_1.1  and 
OIR_06_1.2. 

5.1.1.1.  Cross-compliance 
Cross-compliance aims to ensure that beneficiaries of CAP implement mandatory basic 
standards and requirements by sanctioning non-compliance. As such, cross-compliance is 
considered to be an effective tool for influencing elementary land use and crop/livestock 
management  practices  beneficial  for  natural  resources,  e.g.  through  the  creation  and 
maintenance of buffer strips, the appropriate disposal of hazardous substances, the use of 
catch and cover crops, etc.  In 2019, 84% of  the EU-28 agricultural  area  was subject  to 
cross-compliance. 

48 See footnote 36. 
49 See footnote 37. 
50 CMEF indicator OIR_01a_2.11. 
51 CMEF Indicator CTX_SEC_19_1b. 

26 

 
 
 
                                                      
Data  suggest  that  the  compliance  rate  of  farmers  with  GAECs  varies  only  marginally 
with respect to the specific conditions. But it is estimated to be high, as only 1 to 4% of 
farmers  have  been  found  to  be  non-compliant.  By  maximising  the  number  of  farmers 
under  horizontal  measures,  elementary  practices  that  promote  sustainable  management 
practices  and  sustainable  land  use  spread  more,  therefore  setting  a  regulatory  and 
environmental baseline in the EU. 

Figure 6 Compliance of farmers with GAEC requirements (2015, average) 

100%

99%

98%

97%

96%

95%

GAEC 1 GAEC 2 GAEC 3 GAEC 4 GAEC 5 GAEC 6 GAEC 7

Source: Directorate-General for Agriculture and Rural Development based on the water evaluation support study 

As for the actual effects of cross-compliance, the studies on biodiversity, soil and water 
point mainly to indirect effects, with some exceptions. 

GAEC 1 – Establishment of buffer strips along watercourses 

GAEC 1  on  the  implementation  of  buffer  strips  has  the  potential  to  effectively  protect 
water  from  pollution  but  also  to  protect  riparian  margins.  However,  the  way  in  which 
Member States implement this rule does not provide sufficient protection to waterbodies 
and does not always prevent pollution from nutrients, soil erosion and pesticides getting 
into  watercourses,  even  if  some  Member  States  have  enforced  stricter  rules.  It  only 
provides a sufficient degree of protection when both chemical and fertiliser application is 
forbidden (e.g. in Germany, Spain, France, the Netherlands, Poland, Finland), and buffer 
strips are covered by vegetation and are wide enough to prevent pollutants transfer into 
water. GAEC 1 can have positive effects by decreasing the risk of soil and bank erosion, 
and reducing leaching and runoff, which also affect the chemical status of water.  

GAEC 2  –  Compliance  with  authorisation  procedures  for  abstraction  of  water  for 
irrigation 

GAEC 2 is less effective because only a few Member States actually verify whether the 
appropriate  means  are  there  to  measure  the  volumes  of  water  that  farmers  withdraw. 
Member  States  check  whether  farmers  have  obtained  a  water  licence,  and  eight  case 
study Member States from the water evaluation support study verify farmers’ compliance 
with  the  authorisation  order  (Spain,  France,  Croatia,  Italy,  the  Netherlands,  Poland, 
Romania, Finland). This is the main instrument that promotes land uses and practices that 
are beneficial for reducing water abstraction through water abstraction control, and it was 
assessed  as  being  effective  in  guaranteeing  farmers’  compliance  with  the  authorisation 
order for water abstraction.  

GAEC 3 – Protection of groundwater against pollution 

GAEC 3  targets  water  pollution  by  prohibiting  the  direct  or  indirect  discharge  of  some 
substances  in  water.  In  addition  to  this  requirement,  some  Member  States  verify  other 
aspects under this GAEC, such as the livestock manure storage distance from water (in 
the case studies from  Finland, France and Germany under the water evaluation support 
study, where this measure was the most effective), the proper disposal of pollutants and 

27 

 
 
 
the  absence  of  leakage  storage  tanks  (in  Germany).  According  to  the  case  studies,  this 
GAEC’s  implementation  had  a  direct  and  positive  effect  on  fostering  land  use  and 
practices  beneficial  for  reducing  pollutants  transferred  by  runoff  and  leakage,  by 
reducing nutrients, organic wastes and chemicals applied on land. Improving the quality 
of water also indirectly affected the quality of the soil by halting its deterioration, though 
this effect is very difficult to measure. 

GAEC 4 – Minimum soil cover 

GAEC 4 directly affects  the sustainable management of natural resources by promoting 
soil  cover  between  the  main  crops  in  nitrate  vulnerable  zones  but  also  by  enforcing 
sufficient  coverage  on  fallow  land  or  after  a  ploughing  or  the  removal  of  permanent 
crops, thus reducing soil erosion. It effectively contributes to the sustainable management 
of  water  in  the  context  of  crop  and  livestock  management  by  influencing  soil  structure 
and helps to reduce soil and bank erosion and decrease the risks of runoff and leaching. 
And  while  this  also  has  positive  effects  on  the  sustainable  management  of  soil,  the 
evaluation support study on soil at EU level found that in practice the effects on soil were 
limited, despite GAEC 4’s potential. Some local positive effects limiting soil erosion and 
limiting the loss of soil organic matter linked to the use of soil cover were shown in some 
of the case studies from the study on soil, but with marginal effects, especially in erosion 
‘hotspots’. This GAEC can also encourage the planting of cover crops, though indirectly. 
This has led to improved management by farmers and increased productivity. 

GAEC 5 – Land management to limit soil erosion 

Limiting  erosion is  key  for soil quality, and  GAEC 5 can  encourage practices and land 
use  beneficial  for  soil  sustainability.  Sustainable  management  of  the  nutrient  balance 
(through maintenance and the creation of landscape elements) and practices limiting soil 
compaction (reduced tillage and no-tillage, but marginal effect) were found to reduce soil 
erosion  overall  and  therefore  be  positive.  Although  this  GAEC’s  effect  could  not  be 
quantified,  the  interviews  in  the  case  studies  revealed  positive  effects  reported  locally 
(e.g. Greece has implemented standards within GAEC 5 by prohibiting surface irrigation 
on plots with >10% slopes). 

GAEC 5  also  affected  water  retention,  though  indirectly,  as  Member  States  can  forbid 
ploughing  in  specific  contexts  (depending  on  the  slope  or  climatic  conditions)  and 
sanction  any  activities  likely  to  cause  soil  erosion  (e.g.  overgrazing  in  Finland).  In 
practice,  requirements  under  this  GAEC  are  quite  different  in  the  case  study  Member 
States.  

GAEC 6 – Maintenance of soil organic matter 

GAEC 6 refers only to the absence of any burning of crop residues. On its effectiveness, 
even though the measure banned burning on all EU arable land, it induced no significant 
changes  in  soil  management  practices  in  the  case  study  areas,  except  in  Greece.  It  had 
marginal  effects  on  promoting 
the 
maintenance/incorporation of crop residues and organic matter and (iii) the application of 
organic  amendments  (compost,  manure),  which  ultimately  had  positive  effects  on  soil 
organic matter.  

tillage  and  no 

tillage, 

less 

(ii) 

(i) 

By promoting the maintenance of soil organic matter, this measure has indirect effects on 
water quality and quantity, because the conservation of soil coverage and organic matter 
reduces  soil  and  bank  erosion  and  decreases  the  risks  of  runoff  and  leaching.  This 

28 

 
 
measure  also  seeks  or  can  also  be  expected  to  provide  benefits  for  soil  fauna,  such  as 
earthworms.  

The evaluation on climate change and GHG emissions found that compared to the 2007-
2013  CAP,  the  number  of  Member  States  adopting  additional  requirements  for  the 
maintenance  of  soil  organic  matter  decreased.  However,  part  of  these  requirements 
(which include: restrictions on entering land when it is waterlogged or frozen; use of crop 
rotations;  not  growing  successive  crops  with  a  high  soil  carbon  demand;  application 
and/or monitoring of organic matter; soil testing; and stubble management) are reflected 
in the 2014-2020 CAP, in the crop diversification obligation under greening. 

GAEC 7 – Retention of landscape features 

GAEC 7 addresses biodiversity through the retention of landscape features and includes 
(since  2013)  a  ban  on  cutting  hedges  and  trees  during  the  bird  breeding  and  rearing 
season,  and  optional  measures  for  avoiding  invasive  plant  species.  It  requires  the 
maintenance of certain landscape features that are expected to have a positive effect on 
both  water  quantity  and  quality.  However,  the  level  of  requirement  depends  on  the 
number  of  landscape  features  (hedges,  ponds,  trees  in  lines,  etc.)  protected  and  on  the 
strictness  of the measure (i.e. on the possibility to  remove some features  provided they 
receive special authorisation).  

The  case  studies  of  the  biodiversity  study  show  that  in  a  number  of  Member  States, 
implementation choices reduced the measure’s environmental benefits. The case studies 
point to a wide variation in uptake, with protection most commonly applied to groups of 
trees (7 Member States out of 10), hedges and isolated trees (6 Member States) and trees 
in a line and terraces (5 Member States); and the only requirement in the Netherlands was 
for farmers to obtain a permit before felling trees. According to the same evaluation, in 
theory,  SMR  2  and  SMR  3  should  make  the  obligation  to  protect  certain  landscape 
features  under  the  Birds  and  Habitats  Directives  more  binding,  although  evidence  that 
this is achieved in practice is lacking. 

SMR 1  –  Protection  of  waters  against  pollution  caused  by  nitrates  from  agricultural 
sources 

SMR 1 is linked to compliance with the Nitrates Directive (91/676/EC). It concerns areas 
in  nitrate vulnerable  zones and is  aimed at ensuring  appropriate  application of (manure 
and  mineral)  fertilisers.  The  area  concerned  varies  between  Member  States.  The  SMR 
has a positive effect on reducing inputs (nutrients, organic wastes and chemicals) applied 
on  land,  thus  increasing  water  quality.  It  also  resulted  in  catch  crops,  and  to  a  lesser 
extent  nitrogen-fixing  crops,  having  to  be  planted  in  all  nitrate  vulnerable  zones.  No 
direct effect on soil and biodiversity has been proven.  

SMRs 2 and 3 - Birds and Habitats Directives 

SMRs 2 and 3 make the obligation to protect certain landscape features under the Birds 
and Habitats Directives more binding. There is evidence from the case studies that some 
Member States are not adequately and/or clearly incorporating the legal requirements of 
the  relevant  provisions  of  the  Directives  into  their  cross-compliance  rules.  More 
specifically,  several  Member  States  were  not  using  cross-compliance  to  require  action 
against  priority  invasive  alien  species;  and  from  the  case  study  countries,  only  three 

29 

 
 
(Hungary,  Latvia  and  Ireland)  have  chosen  to  introduce  cross-compliance  to  protect 
against invasive species, in accordance with the Invasive Alien Species Regulation52. 

SMR 10 – Plant protection products 

SMR 10  is  aimed  at  the  protection  of  groundwater  from  contamination  by  plant-
protection products. The only element verified in all the case study Member States is the 
use of market-authorised products.  Besides this, many aspects (up to 17 in Austria) are 
checked with direct effects (e.g. appropriate means to avoid products drifting outside the 
treated area) or indirect  effects  (e.g. bee protection rules) on water protection.  SMR 10 
therefore seems to play only a minor role in reducing groundwater contamination53. 

5.1.1.2.  Greening 
The  evaluation  on  greening  demonstrated  that  the  impact  of  greening  measures  on  the 
environment  and  climate  is  highly  dependent  on  Member  States’  and  farmers 
implementation choices. Although the greening measures have made a small contribution 
to  improving  the  environmental  performance  of  farming,  far  more  could  be  done  to 
improve their performance. This could be done notably by changing the rules governing 
the  operation  of  the  measures  and  putting  greater  emphasis  in  Member  States  on  using 
the  greening  measures  in  combination  with  cross-compliance  and  rural  development 
measures54.  

Indeed,  greening  measures  can  potentially  exert  a  positive  impact  on  the  sustainable 
management of natural resources due to their wide application (they covered over 78% of 
agricultural  land  in  2018)  and  their  deterrence  effect  in  case  of  non-compliance55. 
However, the studies on biodiversity, soil and water found limited evidence to this effect.  

Ecological focus areas (EFAs) 

In 2019, 69% of arable land in the EU was under an EFA obligation. Between 2015 and 
2019, the number of  hectares of actual  EFAs declined from 10.5 million to 9.5 million 
(-9.4%). The  composition  of EFAs in  arable land changed  during that five-year period, 
with  a  2.4 percentage  point  (pp)  decrease  in  catch  crops  or  green  cover  (to  2.1%)  and 
reductions in nitrogen-fixing crops (-2 pp to 3%). However, land lying fallow remained 
unchanged (at 2.6%) and landscape features increased only marginally (+0.1 pp to 0.6%). 
Buffer strips, strips along forest edges and afforested areas also remained marginal.  

The  evaluation  on  greening  found  that  EFA  elements  can  potentially  benefit  not  just 
biodiversity, their main objective, but also water, soils and climate. Member States were 
given considerable flexibility to choose the pool of EFA options available to farmers, and 

52   Regulation (EU) No 1143/2014 of the European Parliament and of the Council of 22 October 2014 on 

the prevention and management of the introduction and spread of invasive alien species. 

53   There  is  significant  potential  for  further  risk  reduction  through  more  complete  implementation  of  the 
Sustainable Use of Pesticides Directive (2009/128/EC) and, in particular, greater adoption of integrated 
pest  management  (IPM),  including  the  more  widespread  adoption  of  non-chemical  pest  control 
techniques. However, the implementation of IPM has not been assessed under cross-compliance to date, 
and it will not be part of inspections under conditionality under the new CAP. 
54   As observed in the European Court of Auditors Special report 21/2017 on greening. 
55   If  a  farmer  is  found  non-compliant  with  crop  diversification  requirements,  the  surface  eligible  for 
greening measures can be reduced by up to 50%. The same kind of sanction applies to ESPG and EFA 
measures. If the sum of a farmer’s non-compliance  with greening measures leads to a more than 20% 
reduction  of  their  eligible  area,  no  greening  payment  is  received.  If  this  value  reaches  50%,  extra 
financial sanctions might be applied. 

30 

 
 
                                                      
whether  and  how  to  lay  down  rules  for  their  structure  and  management.  The  European 
Commission concluded in its 2017 report on the implementation of EFA56 that despite the 
considerable  flexibility,  Member  States  do  not  use  this  discretion  to  maximise  the 
policy’s environmental and climate benefits, but rather strive to implement greening in a 
way  which  minimises  the  burden  on  themselves  and  farmers.  In  particular,  the 
predominance of productive EFAs, together with insufficient management requirements, 
reduces  the  potential  benefits  of  greening  for  biodiversity.  The  same  conclusion  was 
made by the European Court of Auditors in its Special Report 21/2017. As a follow up, 
the Commission introduced in 2018 provisions to enhance the environmental delivery of 
greening, including a ban of pesticides and fertiliser on EFA57. 

Three  of  the  most  widely  declared  EFA  elements  in  2019  were:  catch  and  cover  crops 
(accounting  for  55%),  nitrogen-fixing  crops  (23%)  and  fallow  area  (18%).  The 
percentage of EFAs covered by nitrogen-fixing crops decreased from 2017, possibly due 
to the ban on pesticides for these areas introduced in 2018. 

The evaluation on greening shows that for the EU-28, the EFA element that potentially 
can have the greatest net positive environmental and climate impact is land lying fallow, 
with landscape features (i.e. hedges, trees, ponds and ditches), field margins, buffer strips 
and  multiannual  nitrogen-fixing  forage  crops  also  having  the  potential  of  yielding  net 
benefits. However, few benefits are expected from certain EFA elements because of the 
lack of appropriate management requirements (e.g. to prevent pesticide use or nitrogen-
leaching  by  use  of  nitrogen-fixing  crops)  and  the  low  level  of  uptake  (e.g.  the  non-
productive options). Nonetheless, some Member States have put in place requirements to 
bolster  the  environmental  performance  of  EFAs  (e.g.  rules  on  the  post-harvest 
management  of  nitrogen-fixing  crops  in  Spain  and  Germany,  and  the  EFA  equivalence 
scheme under AECMs in Austria).  

In addition,  where the EFA measure has helped slow the decline of multiannual  forage 
legumes,  this  is  expected  to  be  beneficial,  e.g.  in  Spain,  where  traditionally  cultivated 
legumes  provide  suitable  habitats  for  a  wide  range  of  species,  including  wild  bees  and 
other pollinators, and some mammals and birds that are threatened in the EU (even if this 
example is  not  representative for the EU). On the other hand, there  are some examples 
where the EFA measure may be reinforcing the use of certain types of management that 
result in net negative impacts on biodiversity in certain situations (e.g. the replacement of 
overwinter stubble with cover crop mixes over winter).  

The  evaluation  on  greening  also  found  that  the  EFA  requirement’s  net  impact  on 
biodiversity  could  be  much  greater  if  farmers  were  to  coordinate  types  and  spatial 
arrangements  to  form  larger  habitat  patches  (as  larger  areas  tend  to  be  more  resilient, 
hold  more  viable  populations  and  have  greater  species  richness)  and/or  mosaics  of 
complementary habitats. This might also be beneficial from a soil and water management 
perspective, depending on the location of the EFA elements. 

The support study on biodiversity considers that despite the low level of fallow land in 
arable land, there is some indication that the measure may have had  a beneficial effect, 

56  Report from the Commission to the European Parliament and the Council on the implementation of the 
ecological  focus  area  obligation  under  the  green  direct  payment  scheme,  COM/2017/0152  final, 
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM%3A2017%3A152%3AFIN. 

57  Commission Delegated Regulation (EU) 2017/1155 of 15 February 2017. 

31 

 
 
                                                      
due to the stabilisation/reversal of area in 18 Member States, following a negative trend 
in EU fallow area over 2007-2014 (resulting in a 31% loss). Some of the largest increases 
in  fallow  land  occurred  in  Spain.  It  was  one  of  five  Member  States  where  fallow  land 
comprised more than 50% of the EFA area, and where declines in threatened bird species 
had been linked to previous declines in fallow land.  

In addition, the EFA measure has helped to slow the decline of multiannual fodder crops 
in some Member States, such as Spain where the reappearance of traditionally cultivated 
legumes has been reported (e.g. alfalfa, vetches, peas and beans). This provides foraging 
habitat for a wide variety of species, including wild bees and other pollinators, and some 
threatened mammals in the EU.  

However,  the  potential  benefits  of  the  EFA  measure  are  not  fully  realised,  as  the  most 
commonly declared EFA elements (i.e. catch crops and nitrogen-fixing crops) have low 
biodiversity  benefits  for  most  farmland  species,  other  than  soil  fauna,  even  if  they  can 
reduce  water  pollution,  which  benefits  aquatic  ecosystems  and  biodiversity. 
Nevertheless, the ban on using pesticides on these productive areas that has been in place 
since 2018 has significantly improved the benefit of EFAs for biodiversity.  

The study on soil found that although EFAs had very little impact on the establishment 
and  maintenance  of  landscape  features,  the  ban  on  using  plant  protection  products 
(SMR 10) on EFAs had a positive effect on soil management practices and the reduction 
of  soil  pollution.  In  interviews  with  local  authorities  and  farmers  representatives  in  the 
case  study  areas,  the  majority  considered  that  the  EFA  measure  did  not  result  in 
significant  changes  in  farm  management  practices  or  in  the  choice  of  soil  cover. 
Nevertheless,  technical  advisers  underlined  that  the  EFA  measure  helps  to  establish 
relevant cover crops and raise farmers’ awareness of the positive effect of intercrops and 
has also started to improve the mix of species used in the cover. 

According  to  the  study  on  water,  most  of  the  EFA  elements  can  influence  land  use  to 
improve water quality (i.e. landscape features, fallow land, nitrogen-fixing crops, short-
rotation coppices and forest areas) and also positively impact water quantity (aside from 
nitrogen-fixing  crops  and  short-rotation  coppice).  According  to  the  interviewees  in  the 
case  studies,  the  effects  of  EFAs  on  water  quality  are  rather  positive  in  all  case  study 
Member States and highly positive in Aragon (Spain), Croatia and Apulia (Italy).  

Crop diversification 

In 2016, 23.5% of farms produced at  least  3 crops (-1.0 pp from  2013), with  10.3% of 
farms producing 3 crops (-0.6 pp) and 13.2% more than 3 crops (-0.4 pp). The number of 
hectares  of  arable  land  declared  by  farmers  subject  to  crop  diversification  was 
77.7 million hectares in 2019, which corresponds to 74% of arable land in 2019. About 
12% of arable land was exempted from the diversification measures (e.g. organic farms, 
fallow land or grassland).  

The evaluation  on greening established that  by  increasing the number of crops that are 
cultivated,  crop  diversification  not  only  improves  soil  quality  but  may  also  have  some 
effects  on  biodiversity  (particularly  soil  biodiversity),  water  and  climate.  These  effects 
depend on the types of crops grown and when they are grown (e.g. spring-sown versus 
autumn-sown),  with  greater  environmental  and  climate  benefits  achieved  where  multi-
year crop rotations are put in place. In terms of net effects, the measure probably benefits 
biodiversity in the most intensive arable landscapes, especially those dominated by maize 
or winter wheat. But overall the impact is minor due to the low percentage of additional 

32 

 
 
land diversified. The assessment of this effect,  however, does not  take into account  the 
effect of slowing the trend towards greater monoculture. There is some indication that a 
shift from winter to spring crops has been partly encouraged  – to some extent - by this 
measure and this would be beneficial for biodiversity, particularly if stubble is left in the 
ground over winter. Protection of soil from erosion may have improved in countries such 
as  France,  Germany  and  the  Netherlands  where  maize  has  frequently  been  replaced  by 
crops  providing  better  soil  cover,  e.g.  wheat,  barley  and  other  cereals,  or  by  legumes. 
Although this may not always be the case if shorter growing seasons for legumes such as 
peas leave the soil without cover for long or where maize has been replaced with another 
row crop such as sunflowers, as in France. The greatest environmental impact is likely to 
have  been  in  Spain,  since  it  accounts  for  the  largest  area  of  land  on  which  changes  in 
cropping have taken place. Since the main changes were the replacement of cereal crops 
by  legumes,  benefits  for  soil  and  water  quality  and  GHG  emissions  are  likely  to  have 
occurred (the latter two as a result of reduced applications of nitrogen fertiliser). 

The  case  studies  under  the  study  on  biodiversity  did  not  produce  evidence  of  any 
considerable impacts of the crop diversification requirement, which resulted in different 
crops  being  cultivated  on  just  0.8%  of  the  arable  area  in  the  10  case  study  Member 
States. However, the evaluation on climate change and GHG emissions found that while 
crop  diversification  required  changes  of  crop  on  less  than  1%  of  EU  arable  land,  it 
encouraged farmers to maintain diversification and notably had impact in areas with high 
levels  of  mono-cropping.  According  to  the  evaluation  support  study  on  greening,  most 
farmers  who  had  to  diversify  mainly  planted  leguminous  plants  instead  of  cereals,  and 
they  mainly  did  it  in  rotation;  both  practices  were  identified  as  being  positive  for 
adaptation by favouring resilience to pests and droughts and improving soil structure. 

The study on soil  found  that  crop diversification  with  the cultivation  of  nitrogen-fixing 
crops had positive, albeit indirect, effects on the soil organic matter (and increased soil 
productivity as well). The study on water also found indirect benefits for water protection 
(reducing the need for pesticides, increasing organic matter, etc.). But it also established 
that  while  catch  and  cover  crops  have  many  positive  effects  on  water-related  pressure, 
they are already promoted by other instruments (e.g. SMR 1), which therefore limits the 
additional  effect  of  crop  diversification.  On  the  other  hand,  among  the  case  study 
Member States  that decided to  introduce crop-diversification equivalence schemes, two 
(Poland  and  Austria)  decided  to  implement  more  demanding  crop  diversification 
measures through AECMs, which led to improved effects.  

Permanent grassland 

In 2019, EU-28 total utilised agricultural area (UAA) stood at 179.4 million hectares (an 
increase  of  over  1 million  from  2012)  of  which  34.3%  was  permanent  grassland  and 
meadow (+1.1 percentage points)58. 

The  evaluation  on  greening  states  that  the  environmental  and  climate  benefits  of 
maintaining  the  area  of  permanent  grassland  by  limiting  declines  in  the  ratio  of 
permanent grassland to total agricultural area to less than 5% depend on the location and 
type of grassland maintained and the extent to which the grassland that remains in place 
is  ploughed  or  reseeded.  The  changes  in  the  definition  and  eligibility  of  permanent 
grassland  that  were  made  in  the  2013  CAP  led  to  changes  in  the  eligible  area  of 

58   CMEF indicators C.18 Agricultural area (CTX_SEC_18_1 and CTX_SEC_18_2b). 

33 

 
 
                                                      
permanent  grassland  under  protection  and  the  calculation  of  the  ratio.  Where  prior 
authorisation processes are in place, greater environmental and climate benefits are likely 
to  accrue  since  these  provide  the  opportunity  to  assess  the  environmental  and  climate 
impacts of proposed grassland removals and proceed accordingly. 

The  permanent  grassland  ratio  requirement  aimed  at  halting  the  loss  of  grassland. 
However, as of 2019, the comparison ratio registered negative values in 9 Member States 
and  10  regions  of  the  four  Member  States  that  made  regional  calculations,  but  none 
exceeded  the  5%  threshold.  In  most  cases,  though,  the  changes  in  national/regional 
annual ratios under greening and in the ‘comparison ratio’ resulted from a reallocation of 
permanent grassland areas within the terms of the ratio rather than their actual decrease. 
Instead, the figures reflected the combined effects of a substantial increase of/conversion 
to organic permanent grassland and, to a lesser extent, of decreasing permanent grassland 
under the small farmers scheme. It was also affected by changes to agricultural areas.  

While  7  Member  States  deemed  such  situations  sufficient  to  adapt  the  reference  ratio, 
others  did  not  do  so,  resulting  in  lower  or  negative  figures  for  the  ‘comparison  ratio’. 
Between  2015  and  2019,  permanent  grassland  increased  in  17  Member  States,  with  a 
relative  +/-  1%  stabilisation  in  8  Member  States  and  a  decrease  of  more  than  1%  in  2 
Member States (Estonia and the UK). The mechanism of reconversion was activated four 
times in 2 Member States (Cyprus, in 2015 and 2016, and Estonia, in 2016 and 2018) to 
reverse the more than 5% drop in the annual ratio. 

The  case  studies  under  the  studies  on  biodiversity,  soil  and  water  found  that  the 
permanent  grassland  measure  had  positive  effects  on  water  quantity  and  quality. 
However,  these  case  studies  also  acknowledged  that  management  practices  can  be 
detrimental  to  water  quality  (e.g.  ploughing  of  grasslands  increases  the  risk  of  erosion 
and  runoff  and  reduces  their  organic  matter  content).  On  its  effects  on  soil,  the  ban  on 
ploughing  was  paramount  for  acting  on  not  only  carbon  storage  but  also  reducing  soil 
erosion.  

Biodiversity  benefits  were  difficult  to  measure  accurately  due  to  the  definition  of 
permanent  grassland,  along  with  the  ratios  being  calculated  mostly  at  national  level 
(maintaining  the  ratio  alone  provides  limited  biodiversity  benefits  as  it  can  mask 
significant  losses  in  some  areas).  In  countries  where  this  ratio  has  been  calculated  at 
regional level, it has limited overall permanent grassland losses to some degree. Besides 
the positive effect of protecting permanent grassland, Natura 2000 zones include areas of 
high  value  to  nature,  but  also  areas  with  carbon-rich  soil  and  wetlands,  which  are  two 
important aspects for water protection, retention and soil erosion. 

Environmentally sensitive permanent grassland (ESPG) 

The  evaluation  on  greening  considers  that  by  protecting  large  areas  of  permanent 
grassland within the Natura 2000 network from  being ploughed up, the  ESPG measure 
has  the  potential  to  result  in  substantial  and  wide  environmental  benefits,  given  the 
importance  of  these  areas  for  biodiversity,  soils,  water  and  climate  objectives.  This 
measure  therefore  has  the  potential  to  complement  the  protection  under  the  Birds  and 
Habitats Directives. However, the potential benefits of the ESPG measure are limited by 
the low area of sensitive grasslands59 designated in many countries.  

59   Permanent  grassland  in  areas  covered by  Directives  92/43/EEC  or 2009/147/EC  can  include  Habitats 
Directive  Annex  I  grassland  habitats  designated  as  a  site  of  Community  interest,  Habitats  Directive 

34 

 
 
                                                      
 
The  evidence  of  how  Member  States  have  designated  ESPG  suggests  that  there  are 
different  interpretations  of  what  constitutes  ‘the  environmentally  most  sensitive  areas’ 
which ‘need strict protection’ under the Direct Payments Regulation. The low levels of 
ESPG  designation  in  some  Member  States  suggest  that  there  is  scope  to  extend  its 
coverage  and  increase  its  impact,  particularly  in  light  of  the  important  challenge  of 
achieving  good  conservation  status  of  these  valuable  grasslands  to  which  the  ESPG 
measure should contribute.  

There is also the potential for wide environmental benefits from the designation of ESPG 
beyond Natura 2000 sites. However, such impacts are currently very limited because the 
option  to  designate  ESPG  outside  Natura  2000  sites  was  only  taken  up  by  5  Member 
States  (Belgium,  Czechia,  Italy,  Latvia  and  Wales(UK)),  of  which  only  Czechia 
designated a significant amount. The combined area was only equivalent to about 2 % of 
the total EU area of Annex I habitats outside the network, and much of the area is already 
protected to some extent under national legislation through the provisions of the Nature 
Directives (in particular Article 6 of the Habitats Directive).  

Evidence from the case studies carried out under the evaluation on greening indicates that 
ESPG designation is nonetheless adding some value within and outside Natura 2000 sites 
as a means of complementing the implementation and enforcement of the  Directives  in 
Member States and helping to reduce the continuing pressure from agriculture. 

From the studies on biodiversity, soil and water it can be derived that the ESPG measure 
is  most  effective  in  Member  States  that  have  a  high  rate  of  ESPG  on  total  permanent 
grassland (Italy, Romania), coupled with the stringent controls associated with the CAP 
and advice through farm advisory services on areas subject to the ESPG requirements.  

5.1.1.3.  Area-based rural development measures 
Agri-environment-climate measure –AECM (M10) 

In 2018, 14% of EU utilised agricultural area received AECM support. Over 2015-2018, 
12-15 million hectares were concerned by AECM support for maintenance of high nature 
value  arable  and  grassland  systems,  the  introduction  of  extensive  grazing  practices,  the 
conversion of arable land to grassland and the creation and upkeep of ecological features 
(e.g. field margins, buffer areas, flower strips, hedgerows, trees).  

Management of fertilisers and pesticides affected approximately 6-9 million hectares and 
cultivation  practices  (soil  cover,  ploughing,  etc.)  between  3-5 million hectares.  Areas 
supported for farm management practices (manure management, crop rotation, etc.) have 
grown steadily from 2 to 5 million hectares between 2015 and 2018. 

There was common agreement by interviewees in case studies of the various evaluation 
support  studies  that  AECM  promote  practices  beneficial  for  natural  resources.  AECM 
target all three focus areas of priority 4 – biodiversity, water and soil, depending on the 
needs identified in the individual RDPs.  

Annex  II  habitats  of  species  which  depend  on  grassland  management  designated  as  a  site  of 
Community  interest  and  Birds  Directive  Annex  I  habitats  of  birds  which  depends  on  grassland 
management designated as a special protected area. 

35 

 
 
                                                                                                                                                              
Figure 7 Evolution of areas funded under AECM sub-measure 10.1 (million hectares) 

2015

2018

 16
 14
 12
 10
 8
 6
 4
 2
 -

Cultivation
practices

Farm
management,
integrated
approaches

Irrigation/drainage Management of

inputs incl.
integrated
production
(reduction of
mineral fertilizers,
reduction of
pesticides)

others

Management of
landscape,
habitats,
grassland, HNV
farming

Source: Directorate-General for Agriculture and Rural Development 

Figure  8  Share  of  standardised  farm  practices  supported  by  M10  and  M11  in  the  RDPs  in 
terms of hectares implemented for the reporting periods 2007-2013, 2014-2020 

Organic farming
Max livestock denisty
conservation of grassland
No chemical plant protection
Other limitations on the use of pesticides (type, timing etc.)
crop diversification
Grass cutting restrictions (timing, number of cuts, etc.)
No mineral fertilizers
Intermediate crops / Cover crops / Catch crops
Max N input per ha
Nutrient Management plan
pasturing
conservation of landscape elements
Crop rotation
buffer strips and landscape elements for flowering and protagonists
Grass cutting obligation
No tillage
no or restricted pasturing (timing, species etc.)
Low tillage/mulching
buffer strips along superficial water bodies
Max P input per ha
crop residues left on soil, leaving stubbles on the field
Limitations on fertilizer timing
Erosion protection permanent crops (green cover etc.)
Conservation of valuable grassland species
Sowing restrictions (plant species, certified seed, no sowing/dates,...)
Cultivation of Legumes
No fertilizer use (mineral and organic)
Restriction on tillage timing

Other erosion/runoff protection measures (dams/soil covered with…

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

2014-2020

2007-2013

Source: Joint Research Centre compilation 

Figure  8  presents  the  top  30  farm  practices  supported  by  AECMs  and  organic 
farming in the RDPs in terms of area share for the 2014-2020 period (and 2007-2013 for 
comparison).  In  2014-2020,  the  main  farm  practices  beneficial  to  natural  resources 
supported by AECM relate to limiting livestock density (and pasturing), the conservation 
of grassland, no or reduced use of pesticides, crop diversification and crop rotation, grass 

36 

 
 
 
 
cutting restrictions, nutrient management, cover crops and the conservation of landscape 
features.  The  biggest  change  in  the  two  periods  relates  to  the  reduced  share  of  areas 
supported under grassland conservation (-20 pp), maximum livestock density (-17% pp), 
maximum mineral fertilizer and nitrogen input (-16 pp each), as well as increased areas 
supported  under  organic  farming  (+13 pp),  grass  cutting  restrictions  and  restrictions  on 
pesticide use (+11 pp each).  

Extensive  livestock  farming,  buffer  strips,  catch  and  cover  crops  and  crop  residual 
management  are  beneficial  to  water  quality  and  quantitative  management.  However, 
nutrient management plans are beneficial for water quality only. Crop diversification and 
crop rotation are beneficial to soil management. AECM are also used to target support for 
wild  pollinators’  habitats,  to  maintain  existing  semi-natural  habitats  and  landscape 
features and to create new habitats. 

Organic farming (M11) 

The EU organic area  significantly increased  between  2015  and 2019, with  a more than 
75% increase in the area supported under organic farming, and reached a share of 5% of 
UAA  in  2019.  There  is  considerable  variation  across  Member  States  in  the  area  of 
farmland planned for conversion to or maintenance under organic farming, from less than 
1%  in  three  Member  States  (Bulgaria,  Malta,  Romania)  to  more  than  10%  in  eight 
(Czechia, Denmark, Estonia, Italy, Cyprus, Finland, Sweden), and over 25% in Austria.  

Interviewees in case study Member States under the various support studies agreed that 
support  to  organic  farming  contributed  significantly  to  the  development  of  organic 
farming and therefore to a change in management practices. This support had a positive 
impact  on  the  quality  of  water  both  directly  (e.g.  no  synthetic  pesticides  used)  and  to 
some  extent  indirectly  and  was  also  beneficial  to  quantitative  management  (e.g.  crop 
diversification,  increased  soil  coverage,  etc.).  Organic  farming  contributes  to  the 
development of biological pest control and precision farming, thereby reducing the use of 
fertilisers  and  pesticides  (Germany,  Spain,  France,  Croatia,  Italy,  Austria,  Romania, 
Finland), and also contributes to the conservation or soil incorporation of crop residuals 
(Croatia,  Italy,  Austria,  Poland,  Romania,  Finland).  The  measure  also  provides 
measurable benefits for biodiversity, particularly in more intensively farmed landscapes 
and especially in relation to relatively common and generalist species. 

Overall, the studies find that the measure has positive impacts on water  and soil quality 
by promoting the reduction of inputs (fertilisers, pesticides) applied on lands compared to 
conventional  farming  and by promoting practices to  preserve soil structure and organic 
matter in soil. This in turn has a positive impact on reducing erosion, runoff and leaching 
(through sustainable management)60.  

Natura 2000 and Water Framework Directive payments (M12) 

A limited number of Member States assessed in the case studies of the evaluation support 
studies (Germany, Spain, Italy, Austria) used this measure, and it was only in Germany 
that  this  measure  had  a  significant  positive  effect  on  practices  relevant  to  water 
protection.  Complementary  evidence  is  found  in  the  synthesis  of  the  evaluation  of  the 
enhanced  AIR,  according  to  which  the  measure  significantly  contributes  to  carbon 
conservation and sequestration in some Member States. The benefits to biodiversity arise 

60   For an elaborate description of the impacts of organic farming, see   

https://www.thuenen.de/media/publikationen/thuenen-report/Thuenen_Report_65.pdf. 

37 

 
 
                                                      
as  an  indirect  result  of  the  rules  and  management  plans  being  more  environmentally 
ambitious than they otherwise would have been without the measure. In any case, despite 
its  potential,  the  measure’s  actual  effects  are  limited  because  of  its  low  level  of 
implementation.  However,  areas  supported  under  Natura  2000  and  Water  Framework 
Directive  payments 
to 
1.6 million hectares  (+55%)  in  2019.  Overall,  Natura  2000  areas  (including  natural 
grassland) accounted for 1% of UAA in 2018 (stable compared to 2011). 

from  1.1 million hectares 

in  2015 

increased 

(M12) 

Payments to areas facing natural or other specific constraints – ANCs (M13) 

Some  96.6%  of  expenditures,  corresponding  to  78.9%  of  the  beneficiaries  supported 
through  this  measure,  were  nominally  allocated  to  restoring,  preserving  and  enhancing 
ecosystems  (priority  4)  over  the  2015-2018  period.  However,  the  benefits  for  the 
sustainable management of natural resources are difficult to establish, as the measure is 
generally not directly associated with specific management requirements.  

The European Court of Auditors considered that the majority of payments for ANCs are 
not  linked  to  environmental  objectives  and  are  no  more  beneficial  to  farmland 
biodiversity than the basic payment scheme61. However, if land abandonment (one of the 
main  threats  to  biodiversity  and  leading  to  its  loss)  can  be  avoided,  the  specific  local 
biodiversity  can  be  preserved.  ANC  payments  can  clearly  help  to  avoid  land 
abandonment and therefore contribute to biodiversity objectives.  

As recognised in the study on the future of EU livestock, mountain grasslands are often 
characterised  by  greater  plant  and  animal  biodiversity  than  the  wooded  and  shrubby 
formations of these same landscapes, and grazing keeps shrub cover under control. The 
study  found  that  livestock,  especially  ruminants,  can  have  a  positive  impact  on 
biodiversity and soil carbon because they enable the maintenance of permanent grassland 
and  hedges  and  an  optimised  use  of  manure62.  As  such,  ANC  payments  have  a  clear 
impact on biodiversity, because they maintain livestock in mountain areas. 

Investments in physical assets (M4) 

The study on water found that the measure helped to implement sustainable practices on 
water  by  promoting  new  management  practices  (e.g.  minimal  soil  cultivation,  soil 
incorporation  of  crop  residuals)  or  by  promoting  investment  in  irrigation  and  water 
collection  infrastructure.  The  result  was  that  farmers  were  able  to  invest  in  specific 
equipment to limit water pollution but also to better manage the quantity of water 63.  

The  study  found  that  the  measure  positively  affected  the  use  of  water  in  crop  and 
livestock  management  practices.  But  it  also  had  indirect  negative  effects  on  water 
quality,  given  that  the  support  for  artificial  drainage  (in  the  Netherlands  and  Poland) 
contributed  to  pesticides  and  nitrates  being  directly  carried  into  surface  water.  The 

61   European Court of Auditors Review 01 – Tracking climate spending 

https://www.eca.europa.eu/Lists/ECADocuments/RW20_01/RW_Tracking_climate_spending_EN.pdf 
European Court of Auditors Special report 13 – Biodiversity on farmland. 
https://www.eca.europa.eu/Lists/ECADocuments/SR20_13/SR_Biodiversity_on_farmland_EN.pdf. 
62   Dr Jean-Louis Peyraud and Dr Michael MacLeod, ‘Study on Future of EU livestock: how to contribute 

to a sustainable agricultural sector?’, 2020. 

63   However,  there  are  mixed  perceptions;  environmental  experts  claim  that  insufficient  compliance 
controls  and  monitoring  hinder  the  measure’s  effectiveness.  Whatever  the  case,  as  water  basin 
authorities  are  responsible  for  irrigation  authorisations  and  for  monitoring  water  use,  these  possible 
drawbacks are not due to the CAP itself. 

38 

 
 
                                                      
 
in  bigger 

measure can also have drawbacks in the form of investments that increase water use (e.g. 
increased  water  abstraction). 
investments 
Consequently,  the  measure’s  impact  on  other  natural  resources  is  also  minimal  but 
positive because of the indirect effect that reducing soil desalinisation has on improving 
water quality. 

irrigation  systems 

lead 

to 

Investments  in  forest  area  development  (M8)  and  forest-environment  and  climate 
services and forest conservation (M15) 

Despite the potential of forest and agro-forestry  having considerable positive effects  on 
the sustainable management of natural resources, including the prevention of soil erosion 
and allowing water retention in the soil, these measures were less effective because of a 
low  uptake  and  a  limited  focus  on  measures  addressing  biodiversity  objectives  (mostly 
targeting the protection and enhancement of social and environmental ecosystem services 
in  forests).  Only  2  of  the  10  case  studies  in  the  study  on  soil  demonstrated  forest 
management  practices  sustainable  for  soil  (e.g.  in  Czechia,  support  for  introducing 
supplementary  species  in  forests  with  important  anti-erosion  functions).  At  EU  level, 
investments in forest area (M8) reach 2.5% of the UAA and forest services (M15) 0.3%. 
Therefore, the measures had little impact on soil management. 

5.1.1.4.  Knowledge, cooperation and innovation 
Knowledge transfer and information actions (M1 )and advisory farm management and 
relief services (M2) 

The case studies  in the study on water revealed that  increasing  farmers’  awareness  and 
promoting knowledge transfer and information  actions are important  aspects  to  achieve 
water  quality  and  quantity  objectives.  All  case  study  Member  States  programmed 
knowledge  transfer  and  information  actions,  although  less  than  25%  of  the  supported 
actions and training days targeted the relevant priority (4) and focus areas (5D and 5E), 
and only 1.1% targeted focus area 5A on water quantity. However, stakeholders from the 
case  studies  mentioned  that  even  when  training  does  not  focus  on  water  savings  or  on 
water  quality,  these  subjects  are  often  addressed  directly  (e.g.  during  training  on 
economic  performance  to  limit  input  use)  or  indirectly  (e.g.  during  training  on 
conservation  tillage,  since  these  practices  can  affect  soil  organic  carbon  content  with 
effects  on  both  water  quantity  and  quantity).  The  study  on  soil  found  that  the  measure 
had strong effects on promoting soil sustainable practices in those Member States where 
sustainable soil management activities were implemented.  

Support for advisory services benefited 5.5% of EU farmers. As advisory services have 
adopted  a  broader  focus  on  biodiversity,  like  support  for  AECM  schemes,  they  have 
helped  increase  uptake  and  effectiveness  to  improve  the  status  of  all  natural  resources. 
The study on water pointed to positive effects on water when farmers were advised to use 
machinery  limiting  soil  compaction,  to  engage  in  precision  farming  and  manage 
fertilisers and pesticides with more efficient equipment, to apply a nutrient management 
plan and to maintain or create buffer strips (in Finland). In other Member States, effects 
on water have been limited due to delays in the measure’s implementation (Spain, Italy, 
Romania),  or  its  administrative  complexity  (France,  Germany).  The  study  on  soil 
revealed that the measure’s effects on soil were limited at the EU level, and depended on 
the  number  of  Member  States  undertaking  projects  with  soil  management  as  a  main 
objective.  Where  implemented,  the  measure  was  considered  effective  in  helping  to 
address various soil threats (e.g. erosion, compaction, soil organic content).  

39 

 
 
The  case  studies  in  the  study  on  biodiversity  support  the  findings  mentioned  above  on 
both  measures  and  confirm  that  these  measures  help  the  relevant  measures  (cross-
compliance,  AECM,  organic  farming)  have  greater  impact.  But  they  also  confirm  the 
various limitations linked to implementation. 

FAS – Farm advisory system 

According  to  the  study  on  water,  the  FAS  effectively  contributed  to  the  sustainable 
management  of  water  in  half  of  the  case  study  Member  States  (Spain-Aragon,  Croatia, 
the Netherlands, Austria and Poland). In those Member States (except Poland), the FAS 
focused on natural resources issues, with potential positive effects on the chemical status 
of  water,  and  especially  on  water  quantity  status.  The  FAS  also  made  farmers  more 
aware of their obligations under the Birds and Habitats Directives. Advice to farmers is 
crucial, especially when farmers need to significantly change their practices (e.g. to adapt 
to new water-related regulations, to climate change or to changes in societal demand).  

Cooperation (M16)and Support for LEADER local development (M19) 

The  case  studies  under  the  evaluation  support  studies  found  only  a  few  examples 
regarding  the  implementation  of  the  cooperation  measure.  These  examples  concerned 
projects targeting water objectives in Croatia, the Netherlands and Spain (innovation in 
irrigation, preventing floods and ensuring better water quality). In some of the other case 
study  Member  States,  projects  targeting  other  objectives  were  found  to  have  indirect 
effects  on  the  management  of  water  quality  and  quantities,  but  there  was  no  data  to 
quantify their impact on water. Overall, while all Member States used this measure, less 
than  11%  of  the  actions  targeted  the  relevant  priority  (4)  on  restoring,  preserving  and 
enhancing  ecosystems  and  focus  areas  (5D  on  reducing  nitrous  oxide  and  methane 
emissions  from  agriculture,  and  5E  fostering  carbon  conservation  and  sequestration  in 
agriculture  and forestry)  and  1% targeted focus  area 5A (increasing efficiency in  water 
use by agriculture). Cooperation benefited 0.1% of EU farmers.  

The situation is similar with LEADER (M19), which was used in three of the case study 
Member States to promote water management projects (Austria, Romania, Finland).  

5.1.1.5.  Other 
Because  direct  payments  support  farm  income,  they  can  help  to  prevent  land 
abandonment  and  hence  keep  farmers  active,  especially  those  whose  farms  are  less 
profitable. As presented in the findings of a report on ‘the challenge of land abandonment 
after 2020 and options for mitigating measures’, the harmful effects of land abandonment 
could  threaten  the  future  of  semi-natural  habitats.  Under  specific  conditions  and  in 
certain  phases  of  the  abandonment  process,  though,  beneficial  outcomes  might  be 
observed  for  biodiversity  and  habitats64.  The  same  study  acknowledges  the  impact  that 
the  support  for  farm  income  and  competitiveness  has  in  mitigating  land  abandonment, 
while highlighting the detrimental effect of not targeting such support and not specifying 
the level of environmental ambition.  

By  making  support  under  the  basic  payment  scheme/single  area  payment  scheme 
conditional  on  cross-compliance,  direct  payments  contribute  indirectly  to  natural 

64   ÖIR  GmbH,  BAB,  RegioGro,  ‘Research  for  AGRI  Committee  -  The  challenge  of  land  abandonment 

after 2020 and options for mitigating measures’, 2020 
 https://www.europarl.europa.eu/thinktank/en/document.html?reference=IPOL_STU(2020)652238. 

40 

 
 
                                                      
resource  objectives  addressed  through  SMRs  and  GAECs,  as  described  in  the 
corresponding  section  on  cross-compliance.  In  addition,  the  absence  of  basic  payments 
could lead to the abandonment of small diversified holdings, mostly in grass-fed animal 
sectors  and  in  ANC  areas,  or  to  the  conversion  of  these  farms  to  arable  crops,  which 
would  have  negative  effects  on  water  and  soil  (e.g.  reduction  of  permanent  grassland). 
This is substantiated in the Scenar 2030 report on ‘Pathways for the European agriculture 
and  food  sector  beyond  2020’,  which  assessed  the  implication  of  a  counterfactual  ‘no 
CAP’  scenario  on  land  use  and  the  environment  (among  other  aspects),  showing  that 
without  the  CAP,  land  abandonment,  including  grassland  would  be  higher  (with  a 
reduction of 6.9% in UAA and 8.8% in grassland area)65. 

It  is  very  possible  that  without  CAP  payments  and  the  attached  compulsory 
conditionality,  environmental  considerations  would  be  neglected  to  the  benefit  of 
economic  objectives.  For  example,  the  presence  of  high  densities  of  trees  or  other 
ineligible vegetation could result in an incentive to remove trees and other vegetation that 
would  otherwise  disqualify  a  beneficiary  from  claiming  payments,  leading  to  habitat 
damage  and  in  some  cases  loss  (especially  habitats  under  the  Habitats  Directive). 
Although the study on biodiversity did not find any recent evidence for such situations, it 
found examples of such incentives during the 2007-2013 CAP period, when substantial 
areas of semi-natural habitats (much of which are high diversity habitats) were deemed 
ineligible  for  direct  payments  because  of  the  presence  of  scrub,  shrubs  and  trees.  The 
case studies under the study highlight that the land eligibility criteria for direct payments 
could  prevent  the  encroachment  of  semi-natural  vegetation  on  agricultural  land,  which 
can discourage the establishment of landscape features, or encourage farmers to remove 
landscape  features  (Belgium-Wallonia,  Spain-Aragon).  These  effects  can  be  avoided  if 
areas are eligible for direct payment and hence subject to cross-compliance.  

On  the  downside,  basic  payments  for  the  sustainable  management  of  natural  resources 
can be negatively perceived, as they are granted to all farms, irrespective of their degree 
of input use. Nonetheless, by decoupling support from production and linking support to 
the respect of standard environmental and climate practices, basic payments do not act as 
an incentive to produce more intensively. Between 2013 and 2017, the UAA managed by 
farms with high input intensity66 per hectare remained stable (36.3%), while the share of 
land managed with medium input intensity (36.5%) increased (+3.9 pp), at the expense of 
the land managed by farms with low input intensity (27.2%). In 2016, 21.7% of the UAA 
in the EU-28 was devoted to extensive grazing, which is 7.7 pp below the 2013 level 67. 

65   R.  M’barek,  J.  Barreiro-Hurle,  P.  Boulanger,  A.  Caivano,  P.  Ciaian,  H.  Dudu,  M.  Espinosa,  T. 
Fellmann, E. Ferrari,  S. Gomez y Paloma, C. Gorrin Gonzalez, M. Himics, K. Louhichi, A. Perni, G. 
Philippidis, G. Salputra, P. Witzke, G. Genovese; Scenar 2030 - Pathways for the European agriculture 
and food sector beyond 2020 (Summary report), EUR 28883 EN, Publications Office of the European 
Union, Luxembourg, 2017  
Scenar 2030 - Publications Office of the EU (europa.eu). 

66   Farm  input  intensity  is  used  as  a  ‘proxy’  of  agricultural  intensification,  meaning  an  increase  in 
agricultural input use (fertilisers, pesticides and feedstuff) per hectare of land. Farms are classified into 
intensity categories according to an estimate of input volume per hectare of UAA. Then, each farm is 
classified according to its average level of input use per ha (high intensity if > 300 constant EUR/ha, 
low intensity if <130 constant EUR/ha, otherwise medium intensity). 

67   CMEF indicator C.33 Farming intensity (CTX_ENV_33_1a-c and CTX_ENV_33_2). 

41 

 
 
                                                      
Figure 9 Share of agricultural area managed by low, medium and high intensity farms, 2017 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

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Source: CMEF indicator C.33 Farming intensity (CTX_ENV_33_1a-c) 

high medium low

In  this  programming  period,  the  level  of  direct  payments  per  ha  received  by  the  10% 
most intensive farms declined by 7% to EUR 475 per hectare in 2016-2018, compared to 
the pre-CAP reform level over 2011-2013. It declined also for more than 50% of farms in 
the  EU.  By  contrast,  it  increased  by  close  to  20%  for  the  10%  most  extensive  EU 
farmers,  to  EUR 149 per hectare.  This  is  mainly  the  result  of  internal  convergence  (i.e. 
the obligation for Member States to reduce the differences in the direct payment level per 
hectare). 

Figure 10 Level of direct payment per hectare by class of intensification (EUR/ha) 

500

400

300

200

100

0

Very
extensive
Q1

Q2

Q3

Q4

Q5

Q6

Q7

Q8

Q9

2011-13

2016-18

Very
intensive
Q10

Note:  

Farms are classified according to their level of intermediate costs68 per hectare. The deciles are determined 
based on the population in such a way that there are equal numbers of farms represented in each decile. 

Source:   Directorate-General for Agriculture and Rural Development, based on FADN data 

68   It  covers  total  specific  costs  (fertilizers,  plant  protection  products,  seeds,  feed  for  livestock,  other 
specific  crop  and  livestock  costs)  and  farming  overheads  not  linked  to  a  specific  agricultural  activity 
such  as  energy,  contract  work,  machinery  and  buildings  maintenance,  water,  insurance  and  other 
farming overheads. 

42 

 
 
 
 
                                                      
 
 
 
The  level  of  direct  payments  per  hectare  remains  3  times  higher  for  the  10%  most 
intensive  farms  compared  to  the  10%  most  extensive  ones.  However,  by  contrast,  the 
direct payments per worker at EUR 1 900 are close to 78% lower for the most intensive 
farmers69  than  for  the  most  extensive  ones  (EUR 7 700).  In  addition,  direct  payments 
represent  6%  of  the  income  of  the  10%  most  intensive  farms,  while  it  represents  up  to 
45% of the income of the 10% of most extensive farms (reaching 61% and accounting for 
the  support  to  areas  facing  natural  constraints  and  payments  for  agri-environmental 
commitments). 

Figure 11 Income and subsidies by worker by class of intensification 

EUR/FTE

Coupled DP (/FTE)

Decoupled DP (/FTE)

ANC (/FTE)

Other RD (/FTE)

Income per worker (FNVA/FTE)

35.000

30.000

25.000

20.000

15.000

10.000

5.000

0

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Very extensive Q2

Q3

Q4

Q5

Q6

Q7

Q8

Q9 Very intensive

Note:  

The  income  is  measured  with  the  farm  net  value  added  (FNVA)  by  full  time  equivalent  (FTE).  The 
operating  subsidies  cover  the  coupled  and  decoupled  direct  payments  (DP),  the  support  to  areas  facing 
natural constraints (ANC) and other rural development (RD) support such as agri-environmental payments. 

Source:   Directorate-General for Agriculture and Rural Development, based on FADN data 

Voluntary  coupled  support  has  been  assessed  as  potentially  relevant  to  maintain  some 
specific types of farming beneficial for natural resources, with effects varying according 
to  the  implementation  choices  of  Member  States.  However,  voluntary  coupled  support 
can lead to a higher density of livestock units and increase the corresponding pressure on 
natural resources, like water contamination by nitrates. It is important that Member States 
set eligibility criteria to avoid drawbacks on natural resources, e.g., water. Clear evidence 
of beneficial biodiversity impacts is lacking for most Member States, but there are some 
positive examples from  case studies, e.g. in  the  Netherlands,  the measure is  supporting 
farmers  who  graze  cows or sheep on natural  land (e.g. dunes, heaths  and salt marshes) 
that is otherwise ineligible for direct payments, thereby helping to prevent abandonment 
and  maintain  the  habitats.  Livestock  production  can  have  a  positive  impact  on 
biodiversity  through  the  maintenance  of  permanent  grasslands  and  hedges  and  through 
the  optimized  use  of  manure70.  Regarding  soil,  the  measure  is  considered  to  have 

69   This is linked to the smaller physical average size of the 10% most intensive farms (10 hectares versus 
62 hectares for the 10% most extensive). The 10% most intensive farms are also more labour intensive, 
with on average 2.5 full time equivalent per farm compared to 1.2 for the 10% most extensive. 

70   Dr.  J-L.  Peyraud  and  Dr.  M.  MacLeod,  ‘Future  of  EU  livestock:  how  to  contribute  to  a  sustainable 

agricultural sector’, 2020.  

43 

 
 
 
                                                      
 
 
 
 
 
 
 
 
 
 
 
supported the maintenance of sustainable activities in terms of land use (e.g. maintenance 
of  grassland  in  relation  to  the  measure  for  beef  in  Belgium).  But  representatives  of 
managing  authorities  and  farmers  in  Wallonia  (Belgium)  indicated  that  the  measure  is 
acting as an incentive for intensive farming, and farmer representatives in Spain-Aragon 
indicated that the measure does not prevent land abandonment. Furthermore, for all the 
examples  of  voluntary  coupled  support  found  in  the  case  studies,  none  included 
provisions to limit the supported production’s negative effects on soil. 

With  respect  to  pillar  I  instruments  that  do  not  target  the  objective  of  sustainable 
management of natural resources, a large share of respondents to the public consultation 
could not determine what effect the implementation of the decoupled income support and 
the voluntary coupled support had on natural resources (40% and 43% respectively). For 
sectoral programmes and other CAP instruments, the responses were mixed. But in both 
cases, the highest shares were given to ‘negative effect’ (30% and 32% respectively). 

Figure 12 Effect of pillar I instruments on sustainable management of natural resources 

27%

15%

16%

27%

18%

14%

40%

43%

Decoupled income support (N=179)

Voluntary coupled support (N=176)

27%

26%

18%

25%

30%

25%

Sectoral programmes (N=173)

32%

17%

Any other CAP instrument (N=170)

Positive effect

No effect

Negative effect

Don't know

Source: public consultation14 

Operational  programmes  under  the  common  market  organisation  contribute  to 
sustainable natural resource management objectives by supporting integrated production, 
organic production, actions to conserve soil and actions to create or maintain habitats for 
biodiversity  or  to  maintain  landscapes.  Spending  on  these  actions  has  mostly  declined 
since  2014,  with  the  exception  of  soil  conservation  (+62%  in  2014-2017  compared  to 
2010-2013). Over the same period, spending on integrated production declined by 10%, 
organic production by 54% and habitats by 7%. Case studies for the study on water show 
that  some  Member  States  determined  eligible  criteria  to  ensure  that  installation  and/or 
improvement  of  any  system  supported  in  operational  programmes  for  fruits  and 
vegetables  allows  for  better  management  of  water  resources.  However,  the  diversity  of 
the operations  supported and the lack of information  prevent  an accurate  assessment of 
their effectiveness. 

5.1.1.6.  Overview 
Overall,  support  for  AECM  (M10)  and  organic  farming  (M11)  appear  to  be  the  most 
effective CAP measures contributing to the sustainable management of natural resources, 
with  cross-compliance  providing  a  minimum  level  of  environmental  protection.  Their 
effectiveness is shown to increase when complemented by support to knowledge transfer 
(M1),  advisory  services  (M2)  and  the  provision  of  advice  through  the  farm  advisory 
the 
system.  The 
effectiveness of the instruments and measures.  

implementation  choices  of  Member  States  greatly  determine 

https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-
policy/cmef/farmers-and-farming/future-eu-livestock-how-contribute-sustainable-agricultural-
sector_en. 

44 

 
 
 
                                                                                                                                                              
Responses  to  the  public  consultation  on  the  main  drivers  of  success  in  the 
implementation  of  CAP  instruments  and  measures  for  the  sustainable  management  of 
natural resources  confirm the benefits of ‘voluntary commitments (e.g. AECM, organic 
farming)’  which  received  the  highest  rate  of  responses  (55%).  Considered  next  most 
beneficial were ‘measures targeted and tailored to local context/needs’ (45%) and ‘advice 
(quality,  independence)  and  knowledge  transfer’  (44%),  supported  mostly  by  the 
stakeholder groups: company/business organisations, public authorities and EU citizens. 
Contrary to the findings of the studies, SMRs (29%) and GAECs (23%) did not attract a 
notable level of replies. 

On  the  question  about  the  main  factors  that  limit  the  contribution  to  the  sustainable 
management  of  natural  resources  through  the  implementation  of  the  current  CAP 
instruments  and  measures,  the  answers  imply  significant  limitations  due  to  an 
‘insufficient  level  of  financial  incentives’  (59%),  the  ‘low  ambition  of  the  measures’ 
(44%),  ‘an  insufficient  budget  allocation’,  ‘the  lack/  quality/  independency  of  farm 
advice’ and a ‘disproportionate administrative burden for beneficiaries (fear of excessive 
controls)’ (42% each). On the opposite end, ‘too broad exemptions (i.e. sectors and areas 
excluded  from  requirements)’  (25%),  ‘difficult  eligibility  criteria  to  benefit  from 
measures and/or to access financing (grants, loans, etc.)’ (20%), ‘delay in the payment of 
support’ and ‘too restrictive eligibility and selection criteria’ (19% each) are less limiting 
but do not seem irrelevant either. 

Recent  research  provides  behavioural  evidence  on  the  potential  trade-offs  between 
mandatory and voluntary schemes of the CAP and reveals that more conditionality may 
decrease  farmers’  level  of  enrolment  in  voluntary  schemes.  But  overall  adoption  of 
environmentally  friendly  practices  may  nonetheless  increase  if  there  is  a  substantial 
increase in conditionality71.  

5.1.2.  Input use 

Figure 13 Consumption of inorganic fertilisers (tonnes)  

14.000.000

12.000.000

1.145.572

1.060.785

1.098.736

1.191.769

1.186.919

1.160.6961.185.5241.218.2481.234.291

10.000.000

8.000.000

6.000.000

4.000.000

2.000.000

0
2010

2011

2012

2013

2014

2015

2016

2017

2018

Nitrogen

Phosphorus

Source: Directorate-General for Agriculture and Rural Development on the basis of Eurostat aei_fm_usefert 

71   JRC Science for Policy Report, Farmers and the new green architecture of the EU common agricultural 

policy: a behavioural experiment, 2021.   
https://publications.jrc.ec.europa.eu/repository/handle/JRC123832. 

45 

 
 
 
                                                      
103

102

101

100

99

98

97

96

95

94

93

92

Regarding fertiliser use, in 2018, 11.2 million tonnes of nitrogen and 1.2 million tonnes 
of phosphorus fertiliser were used in EU agriculture, corresponding to a 3% increase in 
the use of nitrogen fertiliser and a 4% increase in phosphorus use compared to 2014. The 
figures show a decline for nitrogen in  2018, but it would be premature to infer that the 
trend is changing72. 

Figure 14 Sales of pesticides in the EU 

Sales of pesticides (2011 = 100)

Sales of pesticides 14 EU Member States, 
percentage change 2018 compared with 2011

120

100

80

60

40

20

0

-20

-40

-60

2011

2012

2013

2014

2015

2016

2017

2018

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Note: Sales of pesticides based on Member States providing data throughout 2011-2018.  
Source: Directorate-General for Agriculture and Rural Development, on the basis of Eurostat (aei_fm_salpest09) 

Consumption of pesticides is measured by the sales of pesticides in tonnes and covers the 
following  plant  protection  products:  fungicides  and  bactericides,  herbicides,  haulm 
destructors  and  moss  killers,  insecticides  and  acaricides,  molluscicides,  plant  growth 
regulators and other plant protection products. Data gaps limit a solid estimation of total 
pesticide use in  the EU, but  available data depicts  relative stability with  annual  swings 
and variations at Member State level. 

With respect to sales by group of substances with various risk categories, in 2018, non-
approved substances declined  to  47 percentage points, while low-risk active substances 
increased to 307 percentage points compared to their 2011-2013 averages. Candidates for 
substitution  and  all  other  approved  substances  increased  slightly,  to  107  and 
109 percentage points respectively73. 

CAP  instruments  and  measures  addressing  the  use  of  plant  protection  products  and 
fertilisers  

Cross-compliance helps to limit the use of fertilisers in nitrate-vulnerable zones (49% of 
EU  arable  land).  As  of  2018,  plant  protection  products  are  banned  on  EFAs  (10%  of 
arable  land).  The  share  of  EFAs  in  arable  land  under  nitrogen-fixing  crops  declined  to 
2.3%  in  2018  from  4.5%  in  2017.  Crop  diversification  produced  limited  effects,  as 
changes  in  cropping  patterns  concerned  a  small  share  of  land  and  did  not  entail  the 
implementation of crop rotation.  

AECMs (M10) also supported the management of inputs on 14% of arable and permanent 
land  in  the  EU  in  2018.  However,  FADN  data  analysis  shows  no  significant  change  in 
fertiliser  or  plant  protection  product  expenses  for  holdings  entering  an  AECM.  FADN 
data  also  shows  that  the  average  share  of  manure  in  fertiliser  expenses  increased  for 

72   Eurostat AEI_FM_USEFERT. 
73   CTX_ENV_48_1a-d. 

46 

 
 
 
 
                                                      
farms entering an AECM in all the case study Member States, except Czechia. But there 
is  no  data  on  the  quantity  of  manure  produced  and  used  on  farms.  Support  for  organic 
farming (M11) helps to  reduce pesticide and fertiliser use, as confirmed by FADN data 
analysis.  The  analysis  depicts  a  tendency  towards  lower  fertiliser  and  plant  protection 
product  expenses  for  farmers  converting  to  organic  farming  in  all  case  study  Member 
States,  except  Italy74.  This  finding  is  supported  in  the  EU  Agricultural  and  Farm 
Economics Brief on Fertiliser input estimates in farms. According to the brief, the use of 
nitrate, phosphorus and  potassium-based soil inputs in  the organic sector is  lower in  all 
sectors, with an especially high gap between organic and conventional farms’ use of these 
inputs in the milk sector75. 

The  case  studies  in  the  study  on  soil  found  examples  of  the  fruit  and  vegetable 
operational  programmes  under the common market  organisation  promoting  a  better use 
of  plant  protection  products  and  fertilisers.  In  Spain-Aragon,  there  was  support  for 
‘generic integrated production’ on 5 326 hectares (2.7% of permanent crops), support for 
using biotechnology or biological control methods instead of conventional ones in fruits 
and  vegetables  cultures  on  937 hectares  and  support  for  using  the  peach-bagging 
technique as a physical barrier against pests on 1 124 hectares. 

The study on water found that the sectors that spend the highest amounts on fertiliser and 
pesticides (i.e. flowers, fruits, vegetables and wine) are not eligible for direct payments in 
several  Member  States  (Germany,  France,  Portugal,  Slovenia,  the  UK).  Therefore  the 
measures  with  the  highest  positive  effects  on  beneficial  agricultural  practices  (notably 
cross-compliance and EFAs) have limited capacity to reduce  fertiliser and pesticide use 
in these sectors. In France and Spain, fertiliser and pesticide reduction is targeted through 
operational programmes of producer organisations in the fruits and vegetables sector.  

In  the  cereals-oilseeds-protein  crops  sector,  cross-compliance  and  greening  measures 
seem to impact fertiliser and pesticide use, except in France and the Netherlands, where 
they  were  assessed  as  ineffective  in  influencing  positive  farming  practices.  Direct 
payments,  and  notably  the  permanent  grassland  greening  measure,  played  a  significant 
role in Germany, Croatia, Austria and Poland for the maintenance of holdings specialised 
in extensive grazing; on average, such holdings have low expenditures in fertilisers and 
pesticides.  

Concrete examples are provided in the summary report of the enhanced AIR submitted in 
2019 (synthesis of chapter 7)76 where numerous managing authorities reported significant 
support  for  better  managing  and  reducing  the  use  of  pesticides  and  fertilisers  in 
agriculture.  Consistent  reductions  of  chemical  inputs  (fertilisers  and  pesticides)  were 
reported  in  Greece,  Croatia,  Brandenburg/Berlin  and  Schleswig-Holstein  (Germany), 
Asturias (Spain), Sardegna (Italy), Slovenia, among other places.  

74   Furthermore,  the  plant  protection  products  allowed  in  organic  farming  are  less  harmful  than  those 

allowed in conventional farming. 

75   EU Agricultural and Farm Economics Briefs No 19, July 2021 - Fertiliser input estimates in farms (An 
overview of costs and quantities of the three main fertilizer components used in the EU farms based on 
FADN data).  
https://ec.europa.eu/info/sites/default/files/food-farming-fisheries/farming/documents/agri-farm-
economics-brief-19_en.pdf. 

76   https://enrd.ec.europa.eu/evaluation/publications/summary-report-synthesis-evaluation-components-

enhanced-airs-2019-chapter-7_en. 

47 

 
 
                                                      
For  instance,  Croatia  reduced  nitrogen  intake  by  4.43%  and  reduced  nitrogen  use  from 
mineral fertilisers by 9.01% in nitrate vulnerable zones, whereas the phosphorous intake 
and the use of phosphorous from mineral  fertilisers were reduced by 5.10% and 9.29% 
respectively.  Aquitaine  (France)  assessed  the  behavioural  changes  among  farmers  in 
terms  of  water  consumption  and  water  pollution  in  their  operation,  showing  that  RDPs 
decreased  the  use  of  inputs  (93%),  reduced  the  nitrogen  fluxes  released  to  the 
environment  (70%),  and  increased  the  efficiency  and  sustainability  of  the  use  of  water 
resources  (60%).  Germany-Sachsen  showed  large-scale  contributions  to  the  material 
discharge  into  water,  thus  improving  its  quality.  In  around  118 900 hectares  of  arable 
land  and  grassland  under  RDP  management  contracts,  no  pesticides  were  used  except 
those permitted in organic farming. Of over 29 900 hectares of grassland managed with 
nitrogen  fertilization,  RDPs  supported  approximately  23 500 hectares  subject 
to 
significant  fertilization  restrictions,  of  which  more  than  14 000 hectares  are  now 
fertilizer-free. Improving erosion protection over grass strips by promoting direct sowing 
and low tillage cultivation methods and having soil covered by arable crops  year-round 
reduced  the  phosphorus  content  buffered  against  substance  inputs  in  arable  land  and 
grass strips. 

5.1.3.  Restoring, preserving and increasing biodiversity 
According to the European Environment Agency, trends in bird and butterfly populations 
can  be  excellent  barometers  of  the  health  of  the  environment,  as  they  are  sensitive  to 
environmental  change,  and  their  population  numbers  can  reflect  changes  in  ecosystems 
as well as in other animal and plant populations.  

Figure 15 Farmland birds and grassland butterflies indices (2000=100) 

97,8
98,1 96,3 94,7 93,2
88,7

96,4

77,2

110

100

90

80

70

60

50

97,6

95,1

91,8 90,5 89,3 88,2 87,1 86,2 85,3 84,6 83,9 83,3 82,7 82,381,9

78,1

72,3 73,8

64,0

54,9

78,9

68,1

66,8

64,5

74,7

69,5

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Farmland birds index

Grassland butterflies population index

Source:  CMEF  C.35  Farmland  birds  index  (CTX_ENV_35_1)  and  European  Butterfly  Monitoring  Scheme  (index 
rebased to 2000=100)  

After  decades  of  dramatic  decline,  the  farmland  birds  index77  displayed  a  gradual 
recovery during the first 3 years of implementation of the 2014-2020 CAP to 85.1. But 
then it fell back in 2017, reaching a new low of 81.8. Comparing the average of the first 4 
years of the 2014-2020 CAP to the preceding four-year average, the index fell by 0.3 pp 
(from  83.8  to  83.5).  For  comparison,  during  the  same  period,  the  common  forest  birds 

77   CMEF indicator C.35 Farmland birds index (CTX_ENV_35_1). 

48 

 
 
 
                                                      
index  (1990=100),  on  the  basis  of  data  from  the  European  Bird  Census  Council, 
displayed a recovery of 6.0 pp78.  

The  grassland  butterflies  population  index  fell  sharply  in  the  first  2  years  of  the  2014-
2020 CAP, but has recovered since. Nonetheless, the 2014-2017 average remains 5.0 pp 
below the 2010-2013 average and 30 pp below the level of the year 200079.  

Figure 16 Conservation status of grassland (% of assessments of habitats) 

50

40

30

20

10

0

-10

favourable

inadequate

bad

unknown

2012

2018

change

Source: CMEF C.36 Conservation status of agricultural habitats; CTX_ENV_36_1a-d 

The data depict a deterioration in the status of habitats. In 2018, the conservation status 
of agricultural habitats (grassland) was deemed ‘favourable’ in 19.7% of assessments of 
habitats  (-1.2 pp  from  2012), compared to  34.0% ‘unfavourable  –  inadequate’ (-4.6 pp) 
and 43.6% ‘unfavourable – bad’ (+5.4 pp), with 2.7% unknown (+0.5 pp).  

In 2015, the area of forest and other wooded land protected for biodiversity, landscape 
and specific natural elements accounted for around 24.5 million hectares and represented 
around  17%  of  the  total  area  of  forest  and  other  wooded  land.  The  share  of  forest  and 
other  wooded  land  protected  to  conserve  biodiversity,  landscapes  and  specific  natural 
elements stood at 12.8% for biodiversity conservation (+0.3 pp from 2010) and 4.2% for 
protection of landscapes and specific natural elements (-4.4 pp).  

Contribution of CAP instruments and measures to CAP objectives on biodiversity  

In  all  of  the  case  study  Member  States  examined  in  the  study  on  biodiversity,  the 
evolution  of  relevant  indicators  and  the  ongoing  declines  in  many  taxa  in  semi-natural 
habitats, and especially in more intensively managed farmland and forests, reveal that the 
CAP instruments and measures are not being used in a way that is sufficient to counteract 
the  pressures  on  biodiversity  from  agriculture  and  forestry  (as  well  as  other  factors 
unrelated to agriculture or the CAP)80.  

78   https://pecbms.info/european-wild-bird-indicators-2019-update/. 
79   Data from European Butterfly Monitoring Scheme. https://butterfly-monitoring.net/. 
80   For  details  on  the  analysis,  see  the  reply  to  evaluation  question  4  in  the  study  on  biodiversity  (see 

footnote 11). 

49 

 
 
 
                                                      
However,  as  also  acknowledged  by  the  European  Environment  Agency,  the  positive 
impacts  of  the  2014-2020  CAP  on  common  species  associated  with  farmland  might 
become visible in the 2020-2030 period81. 

The  share  of  agricultural  land  under  management  contracts  supporting  biodiversity 
and/or landscapes (focus area 4A) reached 17.4% in 2019 (from 5.63% in 2015) and the 
same indicator for forest or other wooded area stood at 0.5%82  

According to  the  summary report of  the  enhanced AIR submitted in  2019 (synthesis of 
chapter  7)63,  the  evaluations  by  managing  authorities  evidenced  that  RDPs  contributed 
somewhat to improving biodiversity and ecosystems with mixed results. Some managing 
authorities estimated positive net effects on the increase of the farmland bird index (e.g. 
Castilla  la  Mancha  (Spain)).  Others  showed  that  RDPs  mainly  helped  to  maintain  the 
population trends in some species stable (e.g. Cyprus). Despite the positive contributions, 
many AIRs stated that the overall decline of the farmland bird index in agriculture was 
not halted (e.g. Czechia, Mainland Finland, Emilia Romagna (Italy)).  

Members States’ evaluations pointed out that RDPs were successful in maintaining and 
enhancing  farming  areas  of  high  nature  value  (HNV)  through  measures  like  AECM, 
organic farming  and Natura2000 (e.g.  La Rioja, Andalucia and  Navarra (Spain),  Lazio, 
Marche, Apulia and Valle D’Aosta (Italy), Latvia, Slovakia, Slovenia). Genetic resources 
in  plants  and  animals  were  preserved  through  RDP  support  (e.g.  in  Castilla  la  Mancha 
and Navarra (Spain), Marche (Italy), Slovenia). 

The  study  on  biodiversity  found  that  a  number  of  case  study  Member  States  (Ireland, 
France,  Portugal  and  Slovakia)  have  focused  their  pillar  II  measures  on  habitats  and 
species, especially in Natura 2000 sites. But the scale of their implementation has often 
been  insufficient  due  to  limited  budgets  allocated  to  AECM  and/or  low  uptake  by 
farmers. The use of the Natura 2000 measure has been very limited, especially in forests, 
and therefore its impact so far has been low. The impact of ESPG is also constrained by 
its relatively low designation in Natura 2000 sites in some Member States and minimal 
ESPG  designation  outside  the  network  in  nearly  all  Member  States.  While  fallow  land 
and/or  low  intensity  multiannual  nitrogen-fixing  forage  crops  in  low  intensity  arable 
farmland are favoured habitats for such species, which can be provided as EFAs, there is 
little direct evidence of the impacts of the measure on relevant species. 

All  case  study  Member  States  used  a  wide  array  of  CAP  instruments  and  measures  to 
protect and maintain grassland habitats and species, to protect farmland birds, to preserve 
and  manage  plant  and  animal  genetic  resources  and  to  minimise  the  impacts  of 
agricultural  pollution  on  biodiversity.  However,  3  Member  States  were  not  using  the 
forest  measures  to  address  pressures  on  forest  habitats  and  species,  3  Member  States 
were not using the CAP to support priority restoration of peatlands and wetlands, and 5 
Member  States  were  not  using  cross-compliance  to  require  action  against  priority 
invasive alien species.  

Through  its  case  studies,  the  study  on  biodiversity  finds  AECMs  (M10)  to  be  the  most 
effective  measure,  particularly  when  it  is  used  to  put  in  place  schemes  focused  on 

81   https://www.eea.europa.eu/data-and-maps/indicators/abundance-and-distribution-of-selected-species-

8/assessment-1. 

82   CMEF  indicators  R.07  Percentage  agricultural  land  under  management  contracts  supporting 
biodiversity  and/or  landscapes  (R.07_PII)  and  R.06  Percentage  forest  or  other  wooded  area  under 
management contracts supporting biodiversity (R.06_PII). 

50 

 
 
                                                      
biodiversity requirements, especially higher-level schemes tailored to biodiversity needs. 
Examples include: 

  Result-based  agri-environment  pilot  schemes  for  habitat  quality,  which  are 
characterised  by  the  annual  payments  to  farmers  being  directly  linked  to  the 
quality  of  the  biodiversity  on  their  farms  (instead  of  compliance).  These  pilot 
projects (seven EU-funded projects in four Member States, 2014-2018) increased 
sustainable  management  of  biodiversity  on  farms.  The  results  were  especially 
successful in Ireland, and farmers generally indicated they would enter a results-
based M10 scheme, if it was available. 

  A  combination  of  broad  conservation  measures  led  to  improvements  in  the 
conservation  status  of  a  dragonfly  (Green  Gomphid,  Ophiogomphus  Cecilia)  in 
Denmark.  All  the  measures  were  taken  to  reduce  nutrient  loads  and  therefore 
support the improvement of the conservation status of numerous aquatic habitats 
and species, including the mentioned dragonfly species. To achieve this, measures 
taken  included  the  protection  of  key  habitats  within  the  Natura  2000  network, 
restoring/improving  water  quality  and  hydrological  regimes  in  large  river 
systems, reducing nutrient loads, restoring key habitats, and reintroducing species 
where needed to restored areas, which were financed. 

 

In  Luxembourg,  through  the  development  of  M10  contracts,  management 
measures extended for grassland habitats in the context of the Eislek LIFE project 
(2012 to 2017). It aimed to restore suitable grassland and wetland habitats in  11 
Natura 2000 sites  to  support nationally endangered butterfly species such as the 
Violet Copper (Lycaena helle).  

Coexistence between farming systems and protected species 

A  wide  range  of  CAP  instruments  and  measures  have  significant  potential  to  support 
improved  coexistence  between  farming  systems  and  protected  species  and  to  raise 
awareness  among  rural  communities  of  the  conservation  value  and  potential  economic 
benefits  of  wild  mammals  and  birds  and  of  agricultural  landscapes  that  are  rich  in 
habitats.  

In  the  specific  areas  and  farming  systems  where  co-existence  is  a  problem,  the  focus 
tends  to  be  on  targeted  investment  in  damage  prevention  and  on  AECM  support  for 
associated extensive, low-input management systems.  

However,  the  opportunity  has  not  been  taken  to  use  a  wider  range  of  CAP  instruments 
and  measures,  for  example  to  provide  specialist  advisory  services,  Natura  2000 
management  plans  and  compensation  payments.  They  could  also  be  used  to  promote 
knowledge  transfer  via  local  cooperation  initiatives  and  landscape-scale  approaches  to 
implementation and to provide support for marketing local products and developing eco-
tourism associated with co-existence efforts.  

Member  States’  CAP  support  for  wild  pollinator  habitats  is  mostly  provided  through 
targeted  AECM  schemes  to  maintain  existing  semi-natural  habitats  and  landscape 
features, to create new habitats, and through the new melliferous fallow option for EFAs.  

However,  implementation  by  Member  States  and  uptake  by  farmers  is  insufficient  to 
meet  the  challenge  of  supporting  recovery  of  the  wild  populations.  No  evidence  was 
found  of  targeted  CAP  support  for  wild  biological  control  agents,  but  the  provision  of 
habitats for wild pollinators is also likely to benefit this group of species.  

51 

 
 
An increasingly important role in coexistence with large carnivores, geese and pollinators 
is  being  played  by  recently  established  EU-level,  national  and  regional  networks  that 
support effective practical cooperation, often bringing stakeholders, farmers and experts 
together to develop and implement management plans and share best practice. 

The  perception  of  respondents  to  the  public  consultation  is  broadly  in  line  with  the 
analysis  mentioned  above,  with  some  differences  in  the  ranking  of  measures.  On  the 
question  on  the  effectiveness  of  the  CAP  instruments  that  contribute  to  the  sustainable 
management  of  biodiversity,  habitats  and  landscapes,  the  measures  perceived  as  most 
effective  were  the  support  to  organic  farming  (47%),  investment  support  for  forestry 
(afforestation, agroforestry) (45%), Natura 2000 (43%) and AECMs (40%).  

On  the  opposite  end,  the  mandatory  practices  without  financial  support  (GAEC)  and 
investment support on farms were perceived as effective ‘to a very small extent’ or ‘not 
at all’ (46% and 45% respectively). 

Figure  17  Effectiveness  of  CAP  instruments  contributing  to  sustainable  management  of 
biodiversity, habitats and landscapes 

12%

14%

20%

30%

6%

18%

Sectoral Programmes for fruit and vegetables (N=172)

13%

12%

22%

30%

6%

16%

Innovation (N=171)

17%

16%

25%

27%

6%

9%

Cooperation (N=171)

14%

16%

23%

22%

8%

18%

Knowledge transfer and advice (N=173)

29%

16%

26%

14%

6%

9%

Investment Support for forestry (N=170)

10%

12%

22%

23%

23%

10%

Investment Support on farms (N=172)

18%

25%

30%

13%

5%

9%

Natura 2000 and Water Framework Directive payments
(N=171)

15%

25%

22%

24%

6%

9%

Support to areas with natural constraints (N=170)

18%

29%

34%

10%

5%

5%

Support to Organic farming (N=173)

9%

24%

18%

20%

9%

21%

Voluntary commitments for forestry (N=173)

22%

18%

28%

18%

8%

6%

Agri-environment-climate voluntary commitments (N=172)

10%

20%

27%

20%

16%

8%

Mandatory practices with financial support (greening) (N=173)

7%

6%

33%

36%

10%

8%

Mandatory practices without financial support (GAEC)
(N=172)

8%

11%

35%

28%

9%

10%

Compliance with non-CAP provisions (SMR) (N=173)

To a very large extent To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation14 

5.1.4.  Preventing soil erosion and improving soil management 
Soil  organic  matter  is  a  key  component  of  soil  as  it  influences  its  structure,  aggregate 
stability,  nutrient  availability,  water  retention  and  resilience.  In  2015,  the  total  organic 
carbon content in arable land stood at 14 065.0 mega tonnes in 2015 (+0.3% from 2012) 
with a mean organic carbon content of 43.1 g/kg (-0.4%)83.  

83   CMEF indicators C.41 Soil organic matter in arable land (CTX_ENV_41_1a and 1b). 

52 

 
 
 
                                                      
Soil erosion by water is one of the most widespread forms of soil degradation in Europe. 
The  results  from  a  study84  on  soil  loss  by  water  erosion  for  the  year  2016  indicated  a 
slight decrease, both in the mean continental soil loss rate (and, as a consequence in the 
total  soil  loss),  and  in  the  area  aﬀected  by  severe  erosion  in  the  2010-2016  period, 
compared to a 9% decrease between 2000-2010. The study considers that the decrease is 
due  to  the  small  increase  of  applied  soil  conservation  practices  in  most  Member  States 
and  some  small  land  cover  changes  (increase  of  urban  areas,  a  minor  decrease  of 
shrublands  and  conversion  of  arable  lands  to  pastures).  However,  CMEF  indicators 
reveal that the share of estimated agricultural area affected by moderate to severe water 
erosion  (>11  t/ha/year)  stood  at  8.0%  of  total  agricultural  area  in  2016  (+1.3  pp  from 
2010)85.  

Contribution of CAP instruments and measures to sustainable soil management 

The share of agricultural land under management contracts to improve soil management 
and/or prevent soil erosion (focus area 4C86) reached 13.8% in 201987 (near to fulfilling 
the common target indicator of 14.3%).  

According to  the  summary report of  the  enhanced  AIR submitted in  2019 (synthesis of 
chapter 7)63, RDPs helped to improve soil management mainly in agricultural land (e.g. 
Czechia,  Baden  Württemberg  (Germany),  Tuscany  (Italy),  Croatia,  Luxembourg). 
However,  since  changes  in  soil  organic  carbon  can  be  observed  only  on  the  long  run, 
only a few AIRs were able to show the RDP impacts already in 2019.  

Positive  contributions  in  preventing  soil  erosion  were  reported  in  numerous  AIRs.  But 
some  managing  authorities  reported  limited  direct  effects  on  the  prevention  of  soil 
erosion  due  to  the  small  coverage  of  interventions  over  the  total  UAA  or  the  low 
targeting of RDP support to areas with higher erosion risks.  

Austria  reported  that  soil  erosion  by  water  was  reduced  by  an  annual  average  of  1.6 
tonnes per hectare (i.e. from 7.5 to 5.9 tonnes), particularly in endangered regions due to 
the  higher  proportion  of  field  crops  with  high  soil  protection  and  organic  farming.  In 
Czechia,  agri-environment-climate  schemes  reduced  the  long-term  average  soil  loss  on 
agricultural  land  by  4.7  tonnes/ha  per  year,  with  positive  effects  on  all  aspects  of  soil 
erosion by water, such as soil degradation, water fouling, and watercourses erosion. 

RDPs  prevented  soil  erosion  in  agricultural  land  mainly  through  organic  farming  (e.g. 
Baden  Württemberg  and  Brandenburg  (Germany),  PACA  (France),  Molise  (Italy))  and 
by  maintaining  woody  elements,  grass  strips,  hedgerows,  or  anti-soil  erosion  systems 
(e.g.  Wallonia  (Belgium),  Basse  Normandie  (France)).  For  example,  Basse  Normandie 
reported  that  agri-environmental  and  climatic  measures  maintained  138  linear  km  of 
hedgerows and 4 km of riparian forest, providing an important anti-erosive impact. 

Various measures supported effective soil management practices, specifically  extensive 
livestock  management  (e.g.  Andalusia  (Spain),  Bolzano  (Italy),  Acores  (Portugal)), 

84   P.  Panagos,  C.  Ballabio,  J.  Poesen,  E.  Lugato,  S.  Scarpa,  L.  Montanarella  and  P.  Borrelli;  A  Soil 
Erosion  Indicator  for  Supporting  Agricultural,  Environmental  and  Climate  Policies  in  the  European 
Union; 2020. 

85   CMEF indicator C.42 Soil erosion by water (CTX_ENV_42_2b). 
86   Preventing soil erosion and improving soil management. 
87   CMEF  indicator  R.10  Percentage  of  agricultural  land  under  management  contracts  to  improve  soil 

management and/or prevent soil erosion (R.10_PII). 

53 

 
 
                                                      
recovery of terraces (e.g. Baleares (Spain)), or rotation of crops (Castilla Leon (Spain)). 
In Liguria (Italy), RDP support to organic farming, integrated farming, and management 
of  permanent  grassland  increased  the  amount  of  organic  matter  by  0.651  tonnes/ha  per 
year.  

Positive  effects  on  soil  erosion  were  attributed  also  to  farm  advisory  actions  (e.g. 
Schleswig Holstein (Germany), Canarias and Castilla Leon (Spain)). 

Achievements  were  also  assessed  in  terms  of  increased  capacity  of  farmers  to  manage 
soil  thanks  to  training  and  farm  advisory  services  (e.g.  Andalucia  (Spain)),  qualitative 
improvement  of  soil  erosion  parameters  (e.g.  Sachsen-Anhalt  (Germany)),  and 
prevention  of  soil  consumption  from  investments  in  physical  assets  (e.g.  Piemonte 
(Italy)). 

The  study  on  soil88  found  that  several  CAP  instruments  and  measures  have  a  positive 
impact  on  soil-quality  components,  but  the  overall  contribution  of  the  CAP  may  be 
limited due to the areas concerned by their implementation. 

The CAP has favoured agricultural practices limiting soil erosion, i.e. soil coverage and 
maintenance of landscape elements, notably through GAEC 1 (buffer strips), EFAs and 
AECMs,  which  help  reduce  runoff  and  erosion  by  wind.  The  literature  and  the  case 
studies  indicate  that  GAECs  4  (soil  cover)  and  5  (land  management),  AECM  (M10.1) 
and  organic  farming  (M11)  could  help  to  reduce  soil  erosion  but  had  a  modest  effect 
because  of  the  limited  area  concerned  by  pillar  II  measures  and  their  low  level  of 
targeting vulnerable areas. 

The EFAs, GAEC 4 (soil cover), AECMs (M10.1) and organic farming (M11) contribute 
to  practices  limiting  the  loss  of  soil  organic  matter  by  promoting  the  use  of  organic 
fertiliser or soil cover. The study could not establish a link between CAP implementation 
over  the  2014-2020  period  and  results  on  soil  organic  matter,  as  the  effect  of  relevant 
practices on soil organic matter can only appear over the long term.  

Soil pollution is mainly tackled by SMRs 1 (nitrates) and 10 (plant protection products), 
EFAs  and  organic  farming  (M11),  which  restrict  the  use  of  fertilisers  and  plant 
protection89  products.  The  maintenance  of  landscape  features  promoted  by  GAEC 1 
(buffer  strips)  and  AECMs  can  also  help  to  reduce  soil  pollution.  Operational 
programmes  specific  to  the  fruits  and  vegetables  sector  and  investment  measures  (M4) 
also  contributed.  Several  managing  authorities  reported  that  pillar  II  measures  allow 
significant support for improving the management and reducing the use of pesticides and 
fertilisers in agriculture; for example in Aquitaine (France) (decreased the use of inputs 
and  reduced  the  nitrogen  fluxes  released  to  the  environment),  in  Belgium  (reduced  the 
use of fertilisers).  

The  key  CAP  instruments  impacting  soil  nutrient  balance  are  SMR 1  (nitrates),  EFAs 
and support for organic farming requirements to  control mineral fertilisers’ application, 
the  GAEC 1  (buffer  strips)  requirement  to  maintain  landscape  features  and  AECMs 
supporting  the  maintenance  of  landscape  elements.  To  a  lesser  extent,  GAECs  4  (soil 
cover), 5 (land management) and 6 (soil organic matter), crop diversification, operational 

88   For details on the analysis, see the reply to evaluation question 4 in the study on soil (see footnote 12). 
89   Error!  Reference  source  not  found.  provides  an  overview  of  CAP  intruments  and  measures 

addressing the use of pesticides and fertilisers. 

54 

 
 
                                                      
programmes  specific  to  the  fruits  and  vegetables  sector  and  investment  measures  (M4) 
also contributed to the implementation of practices and land use sustainable for soil.  

A  direct  link  cannot  be  established  between  changes  in  soil  nutrient  balance  and  the 
effect  of the CAP  implementation. However, the lack of improvement in gross balance 
between  nitrogen  added  to  and  removed  from  agricultural  land  in  the  EU  since  2010 
(while  it  had  decreased  between  2003  and  2015)  imply  a  lack  of  improvement  of  the 
CAP over 2014-2020. 

Figure 18 Reduction in environmental impact indicators (2010=100) 

150

140

130

120

110

100

90

80

70

0
9
9
1

1
9
9
1

2
9
9
1

3
9
9
1

4
9
9
1

5
9
9
1

6
9
9
1

7
9
9
1

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

GHG emissions from agriculture
Gross nitrogen balance
Fertilizers sales*

Ammonia emissions from agriculture
Pesticides sales

Note: Data on fertiliser sales excludes Belgium, Luxembourg and Malta 
Source: Directorate-General for Agriculture and Rural Development 

The impact  of the CAP  measures  and instruments  on  soil compaction and salinisation 
remains very limited, and there is no instrument that clearly addressed this issue.  

Most of the soil-related practices supported by the CAP can be expected to improve soil 
productivity  in  the  long  run.  CAP  measures  and  instruments  promoting  nitrogen-fixing 
crops (e.g. EFAs, pillar  II measures, crop diversification, etc.) have the  greatest impact 
on  productivity.  Other  practices  concern  specific  cases  or  small  areas  and  therefore 
cannot  have  an  impact  on  productivity  at  EU  level.  Conversely,  the  CAP  does  not 
facilitate to a sufficient extent certain practices that can improve soil productivity; these 
include diversified crop rotation, intercropping, mulching, reduced tillage or agroforestry.  

Activities  positive  for  soil  biodiversity  were  fostered  by  SMR 10  (plant  protection 
products),  GAEC 1  (buffer  strips),  AECMs  and  organic  farming  which  promote 
grasslands, the restriction of plant protection products, and landscape features. However, 
the  result  of  CAP  implementation  on  soil  biodiversity  lacks  data,  and  so  the  effect  of 
CAP measures and instruments cannot be established.  

the  public  consultation 
The  perception  of  respondents  expressed 
acknowledges  the  impact  of  the  CAP  on  sustainable  soil  management.  Concerning  the 
question  on  the  effectiveness  of  the  CAP  instruments  that  contribute  to  sustainable 

in  reply 

to 

55 

 
 
 
management of soil resources, the instruments that were perceived as most effective (sum 
of  ‘very  large’  and  ‘large’  extent)  by  the  respondents,  were  the  support  to  organic 
farming (47%), agri-environment-climate voluntary commitments (39%) and mandatory 
practices  with  financial  support  (greening)  (39%).  The  instruments  that  were  perceived 
least  effective  by  respondents  (sum  of  ‘very  small  extent’  and  ‘not  at  all’),  were  the 
investment support on farms (35%), cooperation (33%) and mandatory practices (GAEC) 
without financial support (33%). 

Figure 19 Effectiveness of CAP instruments contributing to sustainable management of soil 

2%

16%

17%

11%

17%

36%

Sectoral Programmes for fruit and vegetables (N=167)

11%

18%

24%

25%

4%

18%

Innovation (N=170)

12%

16%

24%

19%

14%

16%

Cooperation(N=170)

15%

20%

26%

25%

5%

10%

Knowledge transfer and advice (N=172)

16%

18%

14%

20%

13%

22%

11%

25%

22%

22%

29%

28%

18%

6%

20%

Investment Support for forestry (N=171)

19%

16%

10%

Investment Support on farms (N=170)

15%

12%

9%

Natura 2000 and Water Framework Directive…

15%

13%

8%

Support to areas with natural constraints (N=173)

13%

33%

31%

13%

4%

5%

Support to Organic farming (N=172)

7%

20%

25%

20%

6%

23%

Voluntary commitments for forestry (N=169)

17%

23%

31%

20%

5%

6%

Agri-environment-climate voluntary commitments…

12%

27%

23%

18%

10%

11%

Mandatory practices with financial support (greening)…

5%

13%

5%

11%

37%

42%

27%

5%

13%

Mandatory practices without financial support…

15%

14%

12%

Compliance with non-CAP provisions (SMR) (N=172)

To a very large extent To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation14 

5.1.5.  Improving water quality and management 
Water  quality  in  terms  of  gross  nutrient  balance  was,  in  2017,  characterised  by 
49 kg Nitrogen/hectare/year for the potential surplus of nitrogen on agricultural land (no 
change  from  2013)  and  1 kg Phosphorus/hectare/year  for  the  potential  surplus  of 
phosphorus  on agricultural  land (50% reduction from 2013)90. The share  of agricultural 
land  under  management  contracts  to  improve  water  management  (focus  area  4B91) 
reached 14% in 2019 (from 4.4% in 2015)92.  

Impact of CAP instruments and measures on water quality 

In the summary report of the enhanced AIR submitted in 2019 (synthesis of chapter 7)63, 
an improvement in water quality in supported agricultural and forestry land was reported 

90   CMEF indicator C.40 Water quality (CTX_ENV_40_1a and b). 
91   Improving water management, including fertilisers and pesticide management. 
92   CMEF  indicator  R.08  Percentage  of  agricultural  land  under  management  contracts  to  improve  water 

management (R.08_PII). 

56 

 
 
 
                                                      
across  numerous  AIRs.  This  was  often  achieved  through  a  more  sustainable  use  of 
fertilisers and pesticides (e.g. via vocational training, farm advisory services, organic and 
integrated farming, management contracts to improve water quality), as well as  through 
investments  in  physical  assets  to  better  manage  the  discharge  of  by-products  from  the 
livestock sector.  

Positive effects on water quality were reported across several AIRs, for example, in Italy-
Veneto, where the assessment of the gross nutrient balance on agricultural land showed a 
decrease  in  nitrogen  (-42.2%)  and  phosphorous  content  (-20.7%)  in  farms  receiving 
support  from  AECM  (M10)  and  organic  farming  (M11)  compared  to  non-supported 
farms. Similar positive RDP  effects  on the reduction of both  nitrogen and phosphorous 
surplus  were  reported in Estonia, thanks to  the reduction of mineral  fertilisers, whereas 
the RDP implementation did not achieve a significant reduction in the use of pesticides.  

In other cases, RDPs reduced the nitrogen surplus in supported land, while no difference 
was  observed  on  the  phosphorus  surplus  (e.g.  Niedersachsen/Bremen  (Germany), 
Hungary, Greece). Minor RDP effects were also reported, often due to the low targeting 
of measures in protected/vulnerable areas or low level of implementation in forestry land. 
For  instance,  spatial  analysis  in  Latvia  showed  that  management  contracts  to  improve 
water quality are poorly addressing the most sensitive areas (e.g. water bodies at risk and 
Natura 2000 areas). 

Analysis  under  the  study  on  water93  indicates  that  the  measures  helped  to  alleviate 
agricultural pressures in three districts (Finland, Italy and Poland), by reducing fertiliser 
and phytosanitary product expenditures. More modest impacts on reducing phytosanitary 
product  expenditures  or  fertiliser  expenditures  were  identified  in  Germany,  France, 
Croatia, the Netherlands and Romania94.  

Regarding diffuse agricultural pollution, the analysis did not identify a significant effect 
of the measures on the reduction of pollutants transferred by runoff and leakage in any of 
the river basins. This may be due to the latency period for CAP instruments and measures 
implemented since 2014 being insufficient to fully deliver their expected indirect effects 
on  pollutants  transferred  by  runoff  and  leakage,  if  any.  The  same  applies  for  soil  and 
bank erosion, where a clear impact of the water-related CAP instruments and measures is 
lacking.  

In  the  public  consultation,  concerning  the  question  on  the  effectiveness  of  the  CAP 
instruments that contribute to sustainable management of water in terms of water quality, 
the instruments  that were perceived  the most effective were support to  organic farming 
(41%),  Natura  2000  and  Water  Framework  Directive  payments  (39%)  and  agri-
environment-climate-voluntary  commitments  (AECM)  (37%).  The  CAP  measures  and 
instruments  that  were  perceived  the  least  efficient  were  mandatory  practices  (GAEC) 
without  financial  support  (38%),  support  to  areas  with  natural  constraints  (35%)  and 
cooperation (33%). 

93   For details on the analysis, see the reply to evaluation question 4 in the study on water. 
94   See table 43 in the study on water. 

57 

 
 
 
                                                      
Figure 20 Effectiveness of CAP instruments contributing to sustainable management of water 
(quality) 

2%

15%

15%

22%

8%

38%

Sectoral Programmes for fruit and vegetables (N=164)

13%

17%

22%

26%

4%

18%

Innovation (N=168)

13%

11%

23%

26%

7%

20%

Cooperation (N=168)

15%

19%

21%

26%

5%

14%

Knowledge transfer and advice (N=169)

11%

17%

21%

19%

6%

26%

Investment Support for forestry (N=168)

14%

15%

35%

15%

8%

14%

Investment Support on farms (N=170)

12%

28%

25%

20%

3%

13%

Natura 2000 and Water Framework Directive payments
(N=170)

5%

20%

26%

19%

16%

14%

Support to areas with natural constraints (N=168)

14%

27%

34%

9%

5%

11%

Support to Organic farming (N=171)

4%

21%

22%

14%

12%

27%

Voluntary commitments for forestry (N=169)

13%

23%

32%

16%

6%

8%

Agri-environment-climate voluntary commitments (N=171)

10%

16%

32%

20%

13%

10%

4%

12%

34%

31%

7%

12%

Mandatory practices with financial support (greening)
(N=167)

Mandatory practices without financial support (GAEC)
(N=169)

7%

12%

49%

17%

5%

11%

Compliance with non-CAP provisions (SMR) (N=171)

To a very large extent To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation14 

5.1.6.  Increasing efficiency in water use by agriculture 
The  share  of  irrigated  areas  stood  at  5.9%  of  total  UAA  in  2016  (stable  compared  to 
2013)95.  The  European  Environment  Agency  reports  that  agriculture  remains  the  sector 
exerting  the  highest  pressure  on  renewable  freshwater  resources  overall,  being 
responsible  for  59%  of  total  water  use  in  Europe  in  2017  and  mainly  because  of 
agriculture levels in southern Europe96.  

The available data on total water abstraction in agriculture does not allow for a precise 
estimation  at  the  aggregate  EU  level.  But  on  the  basis  of  data  from  12  Member  States 
comparing  the  averages  for  2010-2012/13  and  2014-2016/17,  a  reduction  of  4%  is 
calculated97. However, pressures on water quantity remain at significant pressure levels in 
countries like Spain, which can be seen in Figure 21. 

95   CMEF indicator C.20 Irrigated land (CTX_SEC_20_2). 
96   https://www.eea.europa.eu/data-and-maps/indicators/use-of-freshwater-resources-3/assessment-4. 
97   CMEF  indicator  C.39  Water abstraction  (CTX_ENV_39_1)  for  Bulgaria,  Czechia,  Denmark,  Greece, 

Spain, Cyprus, Lithuania, Malta, Netherlands, Romania, Slovenia and Slovakia. 

58 

 
 
 
                                                      
Figure  21.  Number  of  water  bodies  under  significant  pressure  from  agricultural  water 
abstraction 

Source: European Court of Auditors 

Under the focus area 5A, RDPs aim at increasing efficiency in water use by agriculture. 
Up to 2018, the EU-28 achieved 40.4% of the target value planned for 2023 on the share 
of irrigated land switching to more efficient irrigation systems.  

Impact of CAP instruments and measures on water quantity 

In the summary report of the enhanced AIR submitted in 2019 (synthesis of chapter 7)63, 
only a few (of 44 reporting) managing authorities assessed the CAP contribution on the 
increase of efficiency in water use in agriculture. Among these, efficiency was increased 
in Castilla Leon and La Rioja (Spain), Hungary, Romania, etc. Numerous RDPs helped 
to save water in agriculture through agri-environment-climate measures, the adoption of 
more efficient irrigation systems, or investments to reduce losses in water infrastructure. 
RDP  projects  were  reported  to  have  helped  save  water  in  various  Member  States.  For 
instance, water savings of 25% were reported in Brandenburg-Berlin (Germany), 17% in 
Catalonia, 18% in Castilla-Mancha and 13% in Castilla Leon (Spain) and 11% in Umbria 
(Italy).  Other  examples  included  Portugal-Mainland  (4%  water  savings  in  areas 
benefiting  from  M04  Investments  in  physical  assets  and  9%  water  savings  in  areas 
benefiting from M10 AECM) and Slovenia (26% water savings). 

The analysis  under the  study on water98  found  that  in the river basin  districts  that were 
part of case studies, the total area irrigated increased in Poland, Italy, Austria and Spain 
and decreased in Croatia, Romania and France between 2012/2013 and 2015/2016. The 
reductions in Croatia and France occurred despite high dependency on pillar I support to 
farm types with water-demanding crops (especially maize), while in Romania the reason 
could be due to water-demanding crops replaced by drought-resistant crops99.  

Most  of  the  CAP  measures  and  instruments  that  have  been  assessed  as  efficient  to 
improve water quality can have an effect on water quantity as well, when they improve 

98   For details on the analysis, see the reply to evaluation question 5 in the study on water. 
99   See table 54 in the study on water. 

59 

 
 
 
                                                      
water retention in soil (e.g. reduced tillage), decrease runoff (e.g. soil cover) and enhance 
bank  stabilisation  (e.g.  buffer  strips).  A  specific  water  quantity  issue  is  related  to 
GAEC 2 on water-use authorisation and investments support (M4) granted for irrigation 
systems that are specific tools targeting a more efficient use of water. 

However,  in  its  Special  Report  on  sustainable  water  use  in  agriculture100  the  European 
Court  of  Auditors  considered  that  agricultural  policies  at  both  EU  and  Member  State 
level were not consistently aligned with EU water policy. It noted that few CAP schemes 
linked  payments  to  strong  sustainable  water  use  requirements,  and  systems  for 
authorising  water  abstraction  and  water  pricing  mechanisms  had  many  exemptions  for 
agricultural  water  use101.  The  report  also  concluded  that  the  CAP  supports  projects  and 
practices  expected  to  improve  sustainable  water  use  (such  as  water  retention  measures, 
wastewater  treatment  equipment)  and  projects  improving  the  efficiency  of  irrigation 
systems. However, these are less common than projects likely to increase the pressure on 
water resources (such as new irrigation projects). The report also considered that GAECs 
will  have  no  impact  in  Member  States  with  weak  authorisation  procedures  and/or 
controls. 

The  absence  of  data  makes  it  impossible  to  draw  conclusions  on  the  indirect  effect  of 
water-relevant  CAP  instruments and measures  regarding soil capacity to  increase water 
retention.  For  case  study  Member  States,  in  particular  the  Netherlands,  Poland  and 
Finland,  GAECs  4  (soil  cover)  and  7  (landscape)  as  well  as  ESPGs  were  not  effective 
enough  to  influence  land  uses  and  farming  practices  beneficial  to  the  water-retention 
capacity  of  soil.  On  the  other  hand,  Germany  seems  to  have  seized  the  opportunities 
provided by GAECs and greening provisions to deal with the low soil-retention capacity 
in the Member State102. 

The  effectiveness  of  pillar  II  measures  targeting  focus  area  5A  on  water  abstracted  for 
irrigation cannot be determined. But the observed increase in the water exploitation index 
(WEI+) indicators across all areas indicate worsening water stress situations arising from 
lower  renewable  water  resources  and  higher  water  consumption.  Water-relevant  CAP 
measures  generally  failed  to  deliver  effects  on  water  abstraction,  and  water-demanding 
sectors (such as maize, vegetables, fruits and flowers) benefit from other CAP supports 
under both pillars. 

The  lack  of  homogeneous  data  (time  period  and  scale  considered)  does  not  make  it 
possible to establish a correlation between increased soil organic matter (associated with 
increased  water-retention  capacity)  and  lower  water  consumption  in  the  river  basin 
districts observed in the case studies. 

In  the  public  consultation,  regarding  the  question  on  the  effectiveness  of  the  CAP 
instruments  that  contribute  to  sustainable  management  of  water  in  terms  of  water 
quantity (in %), the instruments that were perceived the most effective were investment 
support on farms (33%), Natura 2000 and Water Framework Directive payments (33%), 
knowledge  transfer  and  advice  (32%)  and  innovation  (40%).  The  CAP  measures  and 

100  European Court of Auditors' Special Report 20/2021 on sustainable water use in agriculture: CAP funds 

more likely to promote greater rather than more efficient water use. 

101  As  described  in  chapters  2  and  3,  the  CAP  contributes  to  the  objectives  of  the  Water  Framework 

Directive through different instruments. 

102  See table 59 in the study on water. 

60 

 
 
                                                      
instruments that were perceived as the least efficient were mandatory practices (GAEC) 
without  financial  support  (35%)  and  linking  CAP  support  to  compliance  with  specific 
non-CAP regulatory provisions (SMR) (35%). 

Figure 22 Effectiveness of CAP instruments contributing to sustainable management of water 
(quantity) 

2%

17%

14%

19%

11%

37%

Sectoral Programmes for fruit and vegetables (N=167)

13%

19%

20%

22%

6%

20%

Innovation (N=172)

14%

14%

19%

25%

8%

21%

Cooperation (N=170)

15%

17%

26%

20%

5%

17%

Knowledge transfer and advice (N=173)

12%

12%

21%

15%

16%

25%

Investment Support for forestry (N=170)

14%

19%

20%

14%

16%

17%

Investment Support on farms (N=170)

9%

25%

26%

20%

6%

14%

Natura 2000 and Water Framework Directive payments
(N=174)

4%

24%

25%

15%

18%

15%

Support to areas with natural constraints (N=171)

8%

21%

24%

16%

17%

14%

Support to Organic farming (N=170)

5%

19%

20%

15%

16%

26%

Voluntary commitments for forestry (N=171)

11%

18%

25%

25%

6%

13%

Agri-environment-climate voluntary commitments (N=173)

5%

20%

26%

20%

16%

14%

6%

5%

32%

29%

11%

17%

Mandatory practices with financial support (greening)
(N=172)

Mandatory practices without financial support (GAEC)
(N=172)

5%

9%

34%

17%

18%

17%

Compliance with non-CAP provisions (SMR) (N=172)

To a very large extent To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation14 

5.2.  Efficiency  

The efficiency of the CAP instruments and measures addressing sustainable management 
of natural resources is assessed by examining whether opportunities exist to improve the 
ratio  of  costs  to  benefits,  and  by  considering  whether  the  administrative  burden  is 
proportionate to the support provided and results obtained. 

The  analysis  is  based  on  data  analysis,  case  studies,  theoretical  reasoning  and  expert 
judgement  in  the  three  studies103,  complemented  by  CMEF  data  and  findings  from 

103  For details on the analysis, see the reply to evaluation questions 9 and 10 in the study on biodiversity, 
evaluation questions 10 and 11 in the study on soil and evaluation questions 9 and 10 in the study on 
water. 

61 

 
 
 
                                                      
previous studies and evaluations, notably a dedicated study on the administrative burden 
of the CAP104 and the evaluation on greening105. 

The  study  on  administrative  burden  mentioned  above  estimated 
the 
administrations the integrated administration and control system (IACS)  costs represent 
around  3%  of  the  annual  CAP  budget106  (3.5-3.9%  of  IACS  managed  CAP  budget), 
which  was  found  to  be  below  overall  European  structural  and  investment  funds. 
Management  and  controls  were  found  to  be  the  highest  proportion  of  the  IACS  costs 
(74%) followed by set-up costs (14%) and running costs (12%). 10% of total IACS costs 
related to greening, 8% to cross-compliance and 32% to rural development. For farmers, 
the  share  of  the  administrative  burden,  excluding  compliance  costs,  accounts  for  about 
2% of the total aid received.  

that  for 

The study concluded that the 2013 reform led to an increase of the administrative burden 
on administrations (attributed mostly to the key novelty of the reform, i.e. the greening, 
e.g. establishing reference layers, acquiring and verifying the data etc.), which has helped 
to avoid a significant increase of the burden on the beneficiaries – the farmers’ interviews 
indicated  no  significant  increase  in  respect  of  administrative  burden.  Specifically  for 
greening, farmers tended to associate compliance and scheme definitions as a source of 
burden rather than the associated administrative tasks.  

The study shows significant differences between Member States covered by case studies, 
depending  on  their  size,  internal  organisation  or  choices  made,  and  also  revealed  that 
there is little data available on the administrative costs related to the CAP implementation 
which makes comparisons between Member States difficult and which did not allow for a 
monitoring of the costs over time. 

The  European  Court  of  Auditors  pointed  out  in  their  2016  report107  that  despite  their 
similarities,  the  compulsory  GAEC  and  greening  rules  are  checked  under  two  control 
systems,  which  may  lead  to  inefficiencies  in  the  control  systems  and  an  additional 
administrative burden. 

According  to  the  replies  to  the  public  consultation,  the  main  aspects  of  administrative 
cost/burden  in  the  implementation  of  the  current  CAP  instruments  and  measures  to 
achieve  the  objectives  relevant  to  sustainable  management  of  natural  resources  fall  on 
beneficiaries (61%), followed by administrations (33%) and others (6%).  

For beneficiaries, the major cost/burden is the ‘complexity to submit an aid application’ 
(36%),  followed  by  ‘too  much  time  and  effort  required  for  administrative  controls’ 
(23%),  ‘too  much  time  required  to  receive  the  payment  after  submitting  the  aid 

104  Ecorys  (2018)  Analysis  of  administrative  burden  arising  from  the  common  agricultural  policy. 

https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-
policy/cmef/regulation-and-simplification/analysis-administrative-burden-arising-common-agricultural-
policy_en. 

105  SWD(2018)478; see footnote 15. 
106  For the budget of the CAP for 2014-2020, see: Error! Reference source not found.3; for the expenditure of 
see 

(Greening 

measures 

relevant 

RDP), 

CAP 

and 

Table 144. 
107  European  Court  of  Auditors  (2016).  Making  cross-compliance  more  effective  and  achieving 

simplification remains challenging. 
https://www.eca.europa.eu/Lists/News/NEWS1610_27/SR_CROSS_COMPLIANCE_EN.pdf. 

62 

 
 
                                                      
 
application’ (21%) and ‘too frequent changes in the policy’ (20%), supported mostly by 
researchers, EU citizens and business organisations.  

For  administrations,  the  clear  source  of  cost/burden  are  ‘too  frequent  changes  in  the 
policy’  (51%),  followed  by  ‘complexity  of  management  in  the  administrative  system’ 
(35%)  and  the  ‘complexity  due  to  a  decentralized  administrative  system’  (14%), 
supported mostly by environmental organisations and EU citizens. 

Overall, most stakeholder groups perceived positively the CAP measures and instruments 
implemented  by  the  Member  States  as  they  generate  the  best  possible  results  on 
management of natural resources with its available budget. It was especially positive for 
public authorities, companies and business associations.  

Cross-compliance 

The study on administrative burden  estimated a cost  range of EUR 130-152 million  for 
cross-compliance at the aggregate (EU) level, concluding that cross-compliance costs as 
a percentage of direct payments received have decreased from 2015 to 2017. As costs of 
controls of cross-compliance are strongly integrated in regular controls of payments, the 
study could not extract what share of costs is related purely to controls of SMRs and/or 
GAECs.  However,  an  indicative  observation  shows,  that  additional  costs  of  SMR 
controls  appear  to  require  1.5%  of  a  full-time  equivalent  per  year.  Costs  incurred  from 
controls  of  GAECs  mainly  arise  through  the  risk-based  sampling  process,  due  to  the 
relatively time-consuming process of establishing the risk profile.  

The  case  studies  conducted  for  the  study  on  soil  included  interviews  with  the  relevant 
authorities in Wallonia (Belgium), Bulgaria, Czechia, Greece, Spain,  Italy and Sweden. 
According  to  them,  the  administrative  management  of  GAECs  4-6  (soil)  has  a  low 
administrative  burden.  Most  of  the  administrative  burden  on  the  farmers’  side  emerges 
from  controls  of GAECs  4-6 (soil).  As for the effects  achieved, the study on soil finds 
that the high administrative burden for GAEC 6 (soil organic matter) is not matched by a 
sufficient  contribution  to  address  soil  organic  matter  conservation.  In  comparison, 
GAEC 4  (soil  cover)  was  assessed  as  effective  on  erosion  and  was  associated  with  a 
smaller administrative burden. 

The study on water finds that the administrative burden generated by water-related cross-
compliance  measures  appears  to  be  appropriately  proportionate  to  the  results  achieved, 
given  the  effectiveness  of  GAECs  1-5  (water  and  soil)  and  SMRs  1  (nitrates)  and  10 
(plant protection products) on water quality and quantity objectives.  

Replies to the public consultation do not provide a positive perception about the extent to 
which cross-compliance generates the best possible results on the management of natural 
resources with its available budget. For SMRs, 24% of 173 replies consider the extent to 
be large or very large, 31% ‘to some extent’, compared to 26% ‘to a very small extent’ 
and  6%  ‘not  at  all’  (and  13%  having  no  opinion).  For  GAECs,  16%  of  169  replies 
consider the extent to be large or very large, 27% ‘to some extent’, compared to 34% ‘to 
a very small extent’ and 11% ‘not at all’ (and 11% having no opinion). 

Greening 

The  study  on  administrative  burden  estimates  a  cost  range  of  EUR 166-186 million  for 
greening at the aggregate (EU) level, making it one of the major cost items of managing 
and control of direct payments.  

63 

 
 
The study finds that a majority of the Member States considers on-the-spot controls for 
EFA  a  major  burden.  This  is  linked  to  the  increased  cost  of  complying  with  control 
requirements and mapping EFA elements in a dedicated land-parcel identification system 
layer (for administrations), the correct declaration of EFA and increased farm inspections 
(for farmers)108. The study also finds that implementation choices by Member States can 
lead  to  overlaps  of  greening  with  other  policies,  including  permanent  grassland  under 
Natura 2000,  Birds  Directive  requirements  under  cross-compliance,  afforested  areas 
under pillar II, as well as regional soil and water protection measures.  

The  study  includes  an  overview  of  farmers’  perspectives  on  administrative  burden, 
collected  through  semi-structured  interviews  of  122  farmers  in  12  case  study  Member 
States. According to the farmers interviewed, the main compliance requirements include 
maintaining  permanent  grassland  and  creating  ecological  focus  areas;  i.e.  compliance 
with rules on prohibitions of phytosanitary products and fertilisers, sowing and ploughing 
dates  in  areas  declared  as  EFAs,  in  particular  for  catch  crops.  Beyond  compliance 
requirements, the main administrative task mentioned by farmers is the measurement and 
declaration of areas corresponding to EFAs. 

On the basis of case studies conducted for the evaluation on greening, private transaction 
costs for farmers are equivalent to 3-9 hours per year per farm and largely independent of 
farm  size,  costing  between  EUR 36-217 million  a  year.  The  evaluation  provides  an 
estimate  of  the  additional  public  administration  costs  of  the  greening  measures  on  the 
basis of a survey of 21 Member States falling between EUR 27-76 million per year at the 
EU-28  level.  This  equates  to  approximately  0.2-0.65%  of  the  value  of  the  budget 
dedicated  to  the  greening  payment  and  between  3%  and  8.5%  of  the  total  public 
administrative cost of direct payments as a whole.  

The  study  on  biodiversity  considers  that  the  administrative  burden  of  creating  and 
maintaining  a  map  of  landscape  features  to  support  their  declaration  as  EFA  is  almost 
certainly disproportionately high at EU level, given that landscape features accounted for 
only 1.7% of declared EFA in 2018 (although much higher in certain Member States) and 
that  many  of  these  were  already  protected  through  GAEC 7  (landscape).  Case  studies 
found  some  examples  of  disproportionate  costs  in  Ireland  (burdensome  mapping 
activities) and Germany (declaration of eligible area).  

The interviews with the relevant authorities in the case studies conducted for the study on 
soil indicate increased administrative burden linked to controls of greening measures in 
Sweden.  As  for  the  effects  achieved,  the  study  on  soil  finds  that  the  administrative 
burden  for  crop  diversification  is  proportionate  with  its  contribution  to  addressing  soil 
organic matter conservation and other soil quality issues.  

According  to  the  study  on  water,  greening  entailed  few  opportunity  costs,  except  for 
highly  specialised  farms,  and  generated  high  administrative  burden  on  the  farmer  side, 
mostly  related  to  the  understanding  of  and  documentation  for  the  greening  rules.  The 
study finds that greening payments are highly efficient and maintain beneficial practices 
for water protection.  

Replies to the public consultation provide a balanced perception of the extent to which 
greening  generates  the  best  possible  results  for  managing  natural  resources  with  its 

108  The  study  could  not  assess  the  administrative  burden  related  to  crop  diversification  and  permanent 

grassland, as the case studies of the study did not provide sufficient data on costs. 

64 

 
 
                                                      
available budget. 33% of 171 replies consider the extent to be large or very large,  24% 
‘to some extent’, compared to 20% ‘to a very small extent’ and 14% ‘not at all’ (and 9% 
having no opinion, they being mainly EU citizens and business associations). 

Pillar II 

The study on the administrative burden estimates  a cost  range of EUR 558-626 million 
for  IACS-based  rural  development  measures  at  the  aggregate  (EU)  level.  Management 
and  control  costs  are  most  frequently  in  a  range  between  5  and  15%  of  the  amount  of 
payments, but variability per Member State is much higher than this range.  

The study finds that the costs of control and administration are particularly high for the 
agri-environmental-climate  measure,  due  to  the  complexity  of  some  types  of  operation 
and changing of eligibility requirements, the potentially numerous and different items to 
be  checked  according  to  the  type  of  commitment  and  the  specific  field  investigations 
required  (late  mowed,  verification  of  fertiliser  /  phytosanitary  inventory  books  and 
storage premises, etc.).   

The  studies  on  biodiversity,  soil  and  water  confirm  the  high  administrative  burden  of 
AECM.  The  case  studies  of  the  biodiversity  study  demonstrated  an  unnecessary 
administrative burden common to Member States linked to the designing of options for 
relevant 
AECMs.  The 
beneficiaries/geographical  areas  regarding  water  issues  has  improved  its  efficiency  in 
some Member States. But in many Member States, the calculation of the payment rate of 
AECMs fails to cover the opportunity cost for highly productive farms, while in others 
(e.g.  Finland,  Croatia  and  Apulia-Italy)  transaction  costs  are  covered  or  limited  (e.g. 
Netherlands).  

targeting  AECMs  on 

study  on  water 

finds 

that 

According to the study on soil, AECMs are the most demanding soil-relevant measure in 
terms  of  administrative  burden,  but  they  also  appear  to  be  the  most  effective  CAP 
instrument  for  soil  protection,  and  therefore  an  efficient  instrument  with  regard  to  this 
cost-effectiveness ratio. The information collected during the case studies show that the 
payment levels provided under AECMs can sometimes hinder its attractiveness, notably 
for highly productive farms (Wallonia (Belgium), Czechia, Bavaria (Germany), Ireland, 
Sweden). However, for most of the stakeholders interviewed, the payment rate of pillar II 
measures relevant for soil was high enough to offset opportunity costs but sometimes too 
low  to  cover  the  administrative  costs  further  incurred  by  beneficiaries  as  part  of 
transaction costs (Italy-Tuscany).  

The study on soil also finds that payment rates under organic farming were generally set 
at an appropriate level to encourage application by farmers and that support for organic 
farming  generates  the  same  pattern  of  high  administrative  burden  and  high  level  of 
effectiveness,  albeit  to  a  lesser  extent  than  AECMs.  Among  the  case  study  Member 
States in the study on water, the support for organic farming promotes farming practices 
that are more remunerative in half of the case study Member States.  

The study on water finds that forest-environment measures and investments in forest 
areas  generate high administrative burden and  generally fail to  cover transaction costs. 
The latter is  contradicted by the  study on soil, according to  which payment  rates under 
forestry investments were generally set at an appropriate level. 

According to the study on water, payment rates granted under knowledge transfer (M1) 
and  advisory  services  (M2)  were  found  to  be  set  at  an  efficient  level,  and  collective 
approaches  (in  Spain,  Croatia,  Austria)  made  it  possible  to  support  more  farmers  at  a 

65 

 
 
lower  cost.  However,  as  also  derived  from  the  case  studies  under  the  study  on 
biodiversity,  the  high  level  of  administrative  burden  associated  with  knowledge  and 
advisory measures often discouraged their implementation or uptake. This is confirmed 
by  the  evaluation  support  study  on  knowledge  exchange,  according  to  which 
administrative burdens for public administrations and intermediate bodies (advisory and 
training bodies) are significant and contributed to the delay in implementation resulting 
in  a  low  uptake  of  measures  (reaching  about  10%  of  the  EU  farms  and  20%  of  CAP 
beneficiaries)109. The situation was very similar for cooperation (M16). 

Regarding  investments  in  physical  assets  (M4),  the  study  on  water  finds  that  the 
payment  rate  was  sometimes  found  to  be  too  low,  and  the  measure  generated  high 
administrative  burden  according  to  case  study  interviewees  (echoed  by  the  study  on 
biodiversity).  The  targeting  of  support  for  water  quantitative  management  under 
investments in physical assets is ensured by eligibility rules for support for investments 
in  irrigation  systems  and  infrastructures,  as  set  out  in  Article  46  of  Regulation  (EU) 
No 1305/2013.  According  to  case  studies,  implementation  of  Article  46  generated 
considerable  administrative  burden  in  some  Member  States  (notably  in  Italy-Apulia).  
However,  the  administrative  burden  can  be  justified  in  this  case  to  ensure  that  the 
investments lead to greater efficiency for the farmer but also that they better ensure the 
environmental benefit to the ecosystem (with some of the water saved going back to the 
water body).    

In its Special Report No 1/2017, the European Court of Auditors found that Natura 2000 
payments did not cover scheme participation costs in some Member States110. 

Overall,  on  the  possibilities  to  reduce  administrative  burden  when  implementing  RDP 
measures, the study on water shows possibilities, in large areas or with a large number of 
farmers involved, in  collective actions, as was the case of the Netherlands with  AECM 
(M10). The  study on soil  showed that Member States  can reduce their own monitoring 
burden111 by using satellite images to improve and facilitate controls when relevant (such 
as for GAEC 4 on soil cover). Lastly, the study on biodiversity shows that Member States 
can  also  reduce  burden  by  not  overlapping  EFA  options  with  existing  GAECs,  which 
would reduce the burden of mapping, and by  reducing or modifying AECM operations 
whose uptake is low. 

Replies to the public consultation confirm the generally positive perception of the extent 
to  which  pillar  II  measures  generate  the  best  possible  results  for  the  management  of 
natural  resources  with  its  available  budget.  Organic  farming  (52%),  AECM  (46%), 
investment support for forestry (46%) and Natura 2000 (44%) are the measures that fare 
best (% replies considering the extent to be large or very large) in the eyes mostly of EU 
citizens, NGOs, public authorities and business associations.  

109  ADE,  CCRI  and  ÖIR  (2020)  Evaluation  support  study  on  the  CAP's  impact  on  knowledge  exchange 

and advisory activities. Brussels.  
policies/common-agricultural-policy/cmef/research-innovation-and-technology/caps-impact-
knowledge-exchange-and-advisory-activities_en. 

https://ec.europa.eu/info/food-farming-fisheries/key-

110  Special  Report  No  1/2017  –  More  efforts  needed  to  implement  the  Natura  2000  network  to  its  full 

potential, paragraphs 59-60. 

111 Area monitoring system. 

66 

 
 
                                                      
Other measures 

The study on soil finds that environmental measures of the fruits and vegetables support 
scheme under the common market organisation are set at appropriate levels to encourage 
application by farmers. Replies to the public consultation provide a positive perception of 
the  extent  to  which  the  sectoral  programmes  for  fruit  and  vegetables  generate  the  best 
possible  results  on  management  of  natural  resources  with  its  available  budget.  29%  of 
172 replies consider the extent to be large or very large, 34% ‘to some extent’, compared 
to 15% ‘to a very small extent’ and 3% ‘not at all’ (and 19% having no opinion).  

5.3.  Coherence 

The assessment of coherence112 of the CAP includes the assessment of CAP instruments 
and  measures  under  the  general  objective  related  to  the  sustainable  management  of 
natural  resources  and  in  particular  biodiversity,  soil  quality  and  water  (internal 
coherence).  The  assessment  of  coherence  also  includes  the  assessment  against  other 
related  EU  and  national  policies  (external  coherence).  An  assessment  of  biodiversity 
related instruments and measures against the other CAP general objectives is provided on 
the basis of the corresponding evaluation support study.  

The  methodology  for  analysing  coherence  is  based  on  theoretical  consistency  checks, 
using  the  relevant  intervention  logics,  previous  studies  and  evaluations,  as  well  as 
findings from case studies (biodiversity and water) and stakeholders (soil). 

The analysis (from the study on biodiversity) shows an overall high level  of coherence 
between biodiversity-related CAP instruments and measures and the other environmental 
objectives of the CAP (water, soil and GHG emissions).  

5.3.1.  Internal  coherence  of  CAP  measures  and 

instruments 

in  addressing 

sustainable management of natural resources 

The  internal  coherence  of  the  CAP  instruments  and  measures  to  support  sustainable 
management  of  biodiversity,  soil  and  water  is  high  and  provides  opportunities  for 
mutually  enforcing  outcomes113.  When  combined,  support  for  AECMs  (M10),  organic 
farming  (M11),  Natura 2000  (M12)  and  investments  in  physical  assets  (M4)  is  more 
effective; and it can be even more effective if also combined with support to knowledge 
transfer  (M1),  advisory  services  (M2)  and  cooperation  (M16)  and  the  farm  advisory 
system. The studies on biodiversity and water also find  further synergistic relationships 
between  the  measures  mentioned  above  and  forest-related  measures  (M8  and  M15). 
Cross-compliance  and  greening  measures  are  also  producing  strong  coherence  and 
contribute to the objectives of biodiversity, soil and water.  

On  the  basis  of  the  case  studies,  the  study  on  biodiversity  finds  interactions  between 
voluntary  coupled  support  and/or  ANC  payments  with  greening  payments,  AECMs  or 
Natura 2000  payments.  Member  State  implementation  choices  of  voluntary  coupled 
support seem to lack any biodiversity-specific focus that these other measures can have 

112  Coherence is understood as how well the CAP works i) internally and ii) with other EU interventions in 

promoting the sustainable management of natural resources. 

113  For  details  on  the  analysis,  see  the  reply  to  evaluation  synthesis  question  11  in  the  study  on 
biodiversity, the reply to evaluation question 13 in the study on soil and the reply to evaluation question 
12 in the study on water. 

67 

 
 
                                                      
(e.g.  stocking  densities).  Only  two  clear  issues  of  incoherence  that  were  found  for 
achieving the CAP’s biodiversity objectives related to certain exemptions.  

Farmers  of  permanent  crops  in  receipt  of  direct  payments  are  not  subject  to  relevant 
greening  practices  but  are  subject  to  cross-compliance  and  receive  support.  Farmers 
under  the  Small  Farmers  Scheme  (SFS)  are  exempted  from  both  cross-compliance  and 
greening requirements. That does not imply that farmers do not implement environmental 
measures;  should  they  apply  for  measures  from  pillar  II  and  likewise,  the  statutory 
management  requirements  part  of  cross-compliance  also  remain  applicable.  These 
exemptions reduce the overall agricultural area subject to cross-compliance and greening 
requirements, which nonetheless remain substantial (84% and 79% of UAA respectively 
in 2019). 

The  study  on  soil  finds  significant  synergies  between  SMR 1  (nitrates)  and  EFA, 
inducing  farmers  to  implement  cover  crops.  Nevertheless,  the  benefits  arising  from 
declared  EFAs  are  limited  where  they  overlap  with  SMR 1  compliant  areas.  This  can 
generate a deadweight, which Member States can act to limit or avoid through additional 
restrictions (such is the case of the Netherlands, where catch crops required under SMR 1 
cannot  be  declared  as  EFAs)114.  The  additional  benefits  from  EFA  in  such  cases  where 
Member  States  do  not  act  to  counter  the  deadweight  are  therefore  limited  compared  to 
the environmental baseline already set by cross-compliance.  

With  respect  to  CAP  instruments  and  measures  not  targeting  sustainable  soil 
management,  certain  eligibility  rules  linked  to  decoupled  direct  payments  indirectly 
hinder  the  establishment  or  maintenance  of  landscape  elements  and  forests,  because 
excluding  areas  from  decoupled  payment  excludes  the  related  greening  obligations.  By 
contrast, decoupled direct payments are granted on drained peatlands, which provides an 
incentive for farmers to  avoid restoring peatlands, despite the significant environmental 
benefits of their restoration.  

Voluntary coupled support can foster nitrogen-fixing crops (increasing soil structure and 
nutrient balance) and help maintain grasslands. But on the other hand, intensive animal-
based  production  can  be  harmful  for  soils  if  grazing  and  manure/slurry  use  are  not 
properly managed. The study on soil also considers that the contribution of payments to 
areas with natural constraints to the maintenance of grassland hinders the alternative of 
land  abandonment,  which  may  produce  spontaneous  reforestation  or  afforestation, 
producing  a  positive  effect  for  soil  protection,  as  soil  erosion  risks  diminish.  However, 
evidence of the effect of land abandonment is rather pointing to the contrary115. 

The  study  on  water  highlights  that  only  a  few  pillar  II  measures  specifically  address 
water issues.  In addition,  sectors with  the  highest  impact  on water quality  and quantity 
(e.g.,  flowers,  wine116)  are  not  constrained  by  the  CAP  framework117  in  some  Member 

114  European Court of Auditors, Special Report No 21/2017 (Greening). 
115  For example, see The challenge of land abandonment after 2020 and options for mitigating measures, 
European  Parliament  Agri  Committee,  2020,  Agnoletti  et  al.,  2019,  Rodrigo-Comino  et  al.,  2018; 
Agnoletti  et  al.,  Terraced  Landscapes  and  Hydrogeological  Risk.  Effects  of  Land  Abandonment  in 
Cinque Terre (Italy) during Severe Rainfall Events (2019); Rodrigo-Comino et al., Contrasted Impact 
of Land Abandonment on Soil Erosion in Mediterranean Agriculture Fields (2018). 

116  This  does  not  apply  to  the  fruit  and  vegetable  common  market  organisation,  as  the  environmental 
framework can support operations for better water management, and more specifically the programme 
provides  support  to  investments  in  irrigation  under  specific  conditions  and  based  on  the  eligibility 
criteria established by the Member State. 

68 

 
 
                                                      
States. Some inconsistencies with regards to the increase of water efficiency use arise, as 
it  is  possible  to  provide  direct  payments  to  highly  irrigated  crop  types  (i.e.,  maize,)  as 
long as they respect the cross-compliance rules. This situation therefore makes it difficult 
to guarantee that funding for irrigation projects will not aggravate the pressure on water 
quantity118, especially if water is scarce. There are also minor issues preventing farmers 
from  participating  in  measures  beneficial  for  water  (i.e.,  it  would  be  environmentally 
beneficial  to  implement  a  flood  attenuation  measure,  allowing  water  to  pool  on 
agricultural land, but such practice would make the land non-eligible for direct payments, 
so farmers will not implement it).  

Overall, restoration practices of more natural morphology or riverbanks would lead to a 
reduction  of  the  land  eligible  for  direct  payments,  hindering  its  possibility  of 
implementation. 

It  is  worth  noting  that  the  evaluation  on  greening  found  greening  measures  to  be 
generally  consistent  with  other  measures  addressing  the  sustainable  management  of 
natural  resources,  particularly  cross-compliance  and  the  agri-environment-climate 
measure.  However,  more  could  be  done  to  make  these  work  together  in  a  synergistic 
way. The evaluation highlighted an issue between the way that the Member States apply 
the CAP eligibility rules and the way they define permanent grassland. 

A significant  share of the respondents  to  the  public consultation  consider that the CAP 
instruments  and  measures  which  contribute  to  the  sustainable  management  of  natural 
resources are coherent, but to varying extents. 59% of respondents (out of 170 replies to 
the question) consider CAP measures and instruments to be coherent with one another in 
addressing the sustainable-management-of-natural-resource objective, with 2% ‘to a very 
large extent’, 17% ‘to a large extent’ and 40% ‘to some extent’. 21% replied ‘coherent to 
a very small extent’, while ‘not at all coherent’ was chosen by 16%.  

The majority of replies from NGOs and environmental organisation expressed criticism, 
and  over  40%  of  citizens  also  consider  that  the  CAP  measures  and  instruments  are 
incoherent,  or  coherent  to  a  very  small  extent.  A  recurring  criticism  concerns  the 
perceived  implementation  deficit  (whether  measures  are  enforced)  and  the  lower 
ambition of Member States due to greening. 

117  Following  the  2003  reform  and  the  decoupling  of  CAP  support,  in  Member  States  implementing  the 
historical  model,  specific  agricultural  sectors  (e.g.  fruits  and  vegetables,  wine)  did  not  benefit  from 
direct  payments  entitlements.  When  they  were  excluded  from  direct  payments,  those  sectors  were 
consequently not forced to comply with GAEC and SMR rules. 

118  European Court of Auditors, Sustainable use of water in agriculture (Audit preview). 

69 

 
 
 
 
 
                                                                                                                                                              
Table  7  Internal  Coherence  of  CAP  measures  and  instruments  in  addressing  sustainable 
management of each of the natural resources 

Biodiversity 

Soil 

Water quantity  Water quality 

Farms advisory system (FAS) 

GAEC 1 (buffer strips) 

GAEC 2 (irrigation) 

GAEC 3 (groundwater) 

GAEC 4 (soil cover) 

GAEC 5 (land management) 

GAEC 6 (soil organic matter) 

GAEC 7 (landscape) 

SMR 1 (nitrates) 

SMR 2 (wild birds) 

SMR 3 (habitats) 

SMR 10 (plant protection products) 

Basic/Single area payment schemes 

Crop diversification 

Permanent grassland 
Environmentally sensitive permanent grassland 
(ESPG) 

Ecological focus area (EFA) 

Voluntary coupled support  

Small farmers scheme 

Knowledge transfer and information actions (M1) 

Advisory services (M2) 

Investments in physical assets (M4) 
Basic services and village renewal in rural areas 
(M7) 

Investments in forest areas (M8) 
Agri-environment-climate measures - AECMs 
(M10) 

Organic farming (M11) 
Natura 2000 & Water Framework Directive 
(M12) 
Payments to areas facing natural or other specific 
constraints – ANC (M13) 

Forest-environment (M15) 

Cooperation (M16) 

See footnote119 

See footnote120 

Legend:   Green – coherent and synergistic; Blue – coherent but very limited synergy;  

Yellow - limited/mixed coherence; Red - incoherent 

Source: Directorate-General for Agriculture and Rural Development 

5.3.2.  External  coherence  of  CAP  measures  and  instruments  in  addressing  the 

sustainable management of natural resources 

The  external  coherence  of  the  CAP  instruments  and  measures  in  addressing  the 
sustainable management of biodiversity, soil and water varies depending on the objective 

119  Some issues in a single case study country (France), as the certification scheme implemented in France 
for  single-crop  maize  growers  can  be  detrimental  to  water,  allowing  farmers  to  continue  maize 
monocropping,  which  results 
in  higher  rates  of  water  abstraction  and  a  concentration  of 
fertilisers/pesticides. 
120  See previous footnote. 

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(external  to  the  CAP)  and  is  influenced  by  the  implementation  choices  of  Member 
States121.  

Overall,  cross-compliance  provides  for  a  high  level  of  coherence,  as  SMRs  introduce 
mandatory conditionality on the basis of relevant non-CAP legislation. A possible risk of 
partial  coherence  or  incoherence  of  pillar  II  measures  derives  from  the  flexibility  of 
national  choices  regarding  their  objectives,  design  and  environmental  conditions.  The 
studies  on  biodiversity,  soil  and  water  share  an  assessment  of  strong  coherence  of  the 
AECMs  (M10)  and  organic  farming  (M11)  with  the  relevant  EU  objectives  on  natural 
resources.  

The  study  on  biodiversity  finds  that  most  of  the  CAP  instruments  and  measures  are 
theoretically  coherent  with  other  related  EU  and  national  policies  relevant  for 
biodiversity.  In  addition  to  the  pillar  II  measures  mentioned  above,  these  include  the 
designation  of  ESPG,  Natura  2000  and  forest  measures,  i.e.  measures  with  the  highest 
potential impacts on biodiversity122. However, the case studies found that a very limited 
ESPG  designation  occurred  outside  Natura 2000  areas,  despite  the  protection  of  semi-
natural grasslands outside the Natura 2000 network being a non-mandatory requirement 
in all Member States. In some Member States (e.g. Hungary and Latvia) there are cases 
where  the  application  of  pillar  II  measures  has  the  potential  to  be  incoherent  with 
biodiversity needs, as they could lead to damaging agricultural improvements (expansion 
or  irrigation)  or  inappropriate  afforestation.  Examples  of  the  latter  could  include 
biodiversity  safeguard  criteria  derogations  to  allow  non-native  trees  to  be  planted  in 
forest areas (Latvia).  

The study on biodiversity  also  identifies relevant objectives of EU instruments that are 
affected  by  the  CAP  and  have  a  significant  role  to  play  in  supporting  EU  biodiversity 
objectives:  the  National  Emissions  Ceiling  Directive  (Directive  (EU)  2016/2284)  on 
limiting  ammonia  emissions,  the  Nitrates  Directive  (91/676/EC)  reducing  water 
pollution,  the  Water  Framework  Directive  (2000/60/EC)  on  protecting,  enhancing  and 
restoring  all  water  bodies,  and  Directive  (2009/128/EC)  establishing  a  framework  for 
Community action to achieve the sustainable use of pesticides. The case studies did not 
find  evidence  of  a  wide  use  of  integrated  approaches  that  combine  funding  from  CAP 
and other sources, with exceptions in Germany and Latvia, where the implementation of 
AECMs is supported using LIFE123 and cohesion funding. 

The  study  on  soil  shows  that  most  of  the  relevant  CAP  instruments  and  measures  are 
theoretically  and  practically  coherent  with 
the  soil-related  objectives  of  EU 
environmental and climate-change policies124. However, the lack of a legally binding EU 
framework  for  soil  means  that  the  coherence  and  complementarity  of  CAP  actions  and 
EU environmental and climate legislation with respect to soils remains highly dependent 

121  For  details  on  the  analysis,  see  the  reply  to  evaluation  synthesis  question  13  in  the  study  on 
biodiversity, the reply to evaluation question 14 in the study on soil and the reply to evaluation question 
13 in the study on water. 

122  Annex  7:  Tables  and  figures  complementing  chapter  5  provides  an  overview  of  the  theoretical 
assessment of the coherence of CAP measures with the Birds and Habitats Directives and actions under 
target 3 of the EU biodiversity strategy. 

123  The  LIFE  programme  is  the  EU’s  funding  instrument  for  the  environment  and  climate  action. 

https://ec.europa.eu/easme/en/life. 

124  Annex 7: Tables and figures complementing chapter 5 provides an overview of the coherence of CAP 

instruments and measures with the EU soil-related objectives. 

71 

 
 
                                                      
on  managing  authorities’ 
implementation  choices.  Implementation  choices  also 
determine  the  synergies  with  soil-related  objectives  of  EU  policies  (e.g.  application  of 
rotation,  the  type  of  crops,  when  they  are  grown,  etc.).  Evidence  from  the  case  studies 
suggest  that  soil-related  issues  were  not  a  major  influencing  factor  in  farmers’  crop 
diversification  choices  (e.g.  Belgium-Wallonia,  Czechia,  Denmark,  Greece,  Italy).  The 
study on soil also shows instances where mixed/conflicting outcomes occur as a result of 
Member  States’  implementation  choices,  e.g.  investment  support  is  used  to  purchase 
specialised  equipment  that  can  improve  soil  quality  by  reducing  the  use  of  inputs  or 
improving efficiency (e.g. Belgium-Wallonia, Spain-Aragon, Ireland, Italy-Tuscany). But 
certain  tilling  and  heavy  spreading  equipment  can  have  negative  effects  in  terms  of 
damaging soil structure and compaction (e.g. Belgium-Wallonia, Ireland, Italy-Tuscany). 

The study on water identifies a partial coherence of the CAP instruments and measures 
dedicated to environment with the general objective of the EU environmental legislation 
and  strategy  (Water  Framework  Directive,  Nitrates  Directive,  Sustainable  use  of 
pesticides  Directive,  etc.)125.  The  study  emphasises  the  CAP’s  role  as  important  in 
promoting  the  objectives  of  the  Water  Framework  Directive  and  points  to  the 
contribution  of  investment  measures  (M4)  in  helping  farmers  to  reduce  water 
consumption  for  irrigation.  The  contribution  of  greening  practices  was  targeted  on 
Climate  Change  and  Biodiversity.  The  study  on  water  also  points  to  instances  of 
incoherence: 

 

limited  number  of  pillar  II  measures  specifically  addressing  water  issues 
implemented by managing authorities; 

  sectors  with  highest  impact  on  water  quality  and  quantity  (e.g.  fruits,  flowers, 

wine) are not constrained by the CAP framework; 

 

inconsistencies  with  trade  agreements  allowing  duty  free  imports  of  oilseeds, 
oilseed  products  and  non-grain  feed  ingredients  that  incentivise  animal  feed 
imports  and  thereby  promote  the  creation  of  concentrated  and  intensive  animal 
husbandry  farms  around  big  ports,  leading  to  a  specialisation  of  regions, 
producing  a  structural  pollution  of  waters  scenario  –  while  the  study  does  not 
substantiate  this  effect,  the  Trade  Sustainability  Impact  Assessment  of  the  EU-
Canada  Comprehensive  Economic  and  Trade  Agreement126  considers  that  the 
expansion in the dairy sector, as a result of trade deals, could worsen the impact 
on water quality from this sector.  

Replies  to  the  public  consultation  do  not  provide  a  clear  and  conclusive  picture  on  the 
extent  to  which  the  applicable  CAP  instruments  and  measures  addressing  sustainable 
management  of  natural  resources  deliver  a  coherent  and  complementary  contribution 
with overall EU environmental and climate change legislation and strategies.  

The  highest  share  of  positive  replies  (sum  of  ‘fully  coherent’  and  ‘mostly  coherent’) 
concern  coherence  with  the  Water  Framework  Directive  (37%),  the  Nitrates  Directive 
(36%)  and  the  Habitats  Directive  (33%).  Although  the  coherence  with  the  Sustainable 
Use of Pesticides Directive received the fourth highest share of positive replies (29%), it 
attracted the highest share of negative replies (32%). 

125  Annex 7: Tables and figures complementing chapter 5 summarises the coherence of CAP instruments 

and measures with the key EU key water and environmental policies and strategies. 

126  Commissioned by the European Commission's Directorate-General for Trade, carried by Development 

Solutions Europe Limited. 

72 

 
 
                                                      
Figure  23  Coherence  with  overall  EU  environmental  and  climate  change  legislation  and 
strategies 

4%

16%

36%

29%

15%

EU strategy on adaptation to climate change (N=167)

2%

8%

36%

23%

31%

Land Use, Land-Use Change and Forestry  (N=167)

1%

5%

20%

16%

58%

Effort Sharing Decision (N=160)

4%

11%

25%

24%

5%

19%

3%

16%

23%

27%

2%

6%

15%

16%

24%

18%

8%

9%

7%

16%

24%

22%

33%

31%

27%

17%

19%

6%

5%

14%

15%

27%

24%

13%

24%

31%

13%

28%

4%

17%

28%

11%

36%

29%

35%

National Emission Ceilings Directive (N=161)

Air quality directive (N=164)

Renewable Energy directive (N=161)

Industrial Emissions Directive (N=162)

15%

12%

13%

EU Biodiversity Strategy to 2020 (N=165)

Habitats Directive and Birds Directive (N=166)

Sustainable Use of Pesticides Directive (N=165)

61%

29%

23%

32%

25%

8%

Nitrates Directive (N=169)

27%

27%

Floods Directive (N=161)

43%

23%

39%

Sewage Sludge Directive (N=164)

12%

Water Framework Directive (N=169)

7th Environment Action Programme to 2020 (N=166)

Fully coherent

Mostly coherent

Somewhat coherent

Incoherent

No opinion

Source: public consultation14 

A large share of  respondents  perceive incoherence with  the EU  biodiversity  strategy to 
2020 (29%) and the EU strategy on adaptation to climate change (29%). As in the replies 
on  internal  coherence,  NGOs  and  environmental  organisation  are  most  critical,  along 
with a considerable share of citizens. On the coherence with the EU biodiversity strategy 
to  2020,  68%  of  NGOs  and  environmental  organisations  and  approximately  40%  of 
citizens  replied  ‘incoherent’,  while  53%  of  public  authorities  gave  a  positive  reply 
(without a single negative reply).  

5.3.3.  Internal  coherence  of  CAP  measures  and  instruments  addressing  sustainable 

management of natural resources with other CAP objectives 

The study on biodiversity assessed the coherence of instruments and measures related to 
biodiversity  with  the  objectives  of  viable  food  production  and  balanced  territorial 
development127.  

In theory, biodiversity instruments and measures could constrain farm operations through 
conditionality and increased costs, and thereby lead to incoherence with the viable food 
objective.  However,  the  study  shows  that  this  rarely  occurs  in  practice.  The  EFA 
obligation  had  little  negative  impact  on  agricultural  income  and  productivity,  because 
Member  States  and  farmers  have  used  the  flexibility  offered  in  the  legislation  to  make 
EFA  choices  in  order  to  avoid  conflicts  with  the  objectives  of  income  and 
competitiveness.  The  greening  crop  diversification  measure  also  had  an  overall  limited 
impact on production. 

127  For details on the analysis, see the reply to evaluation question 12 in the study on biodiversity. 

73 

 
 
 
                                                      
Table 8 Coherence of the CAP's biodiversity measures with its general objectives 

Viable food production 
(agricultural income, agricultural 
productivity, price stability) 

Balanced territorial development 
(rural employment, rural growth, 
poverty in rural areas) 

Sustainable use of natural 
resources and climate action 
(greenhouse gas emissions, 
water and soils) 

Horizontal measures - Regulation (EU) No 1306/2013 

FAS 

SMR 2 (wild birds) 

SMR 3 (habitats) 

GAEC 7 (landscape) 

Pillar 1 - Regulation (EU) No 1307/2013 

Crop diversification 

Permanent grassland 

permanent 

Environmentally 
sensitive 
grassland (ESPG) 
Ecological  focus  areas 
(EFA) 

Pillar 2 - Regulation (EU) No 1305/2013 

M4.4  Non-productive 
investments 

M8.5  Investments  for 
the 
and 
resilience 
environmental value of 
forest ecosystems 
M10 
environment-climate 

Agri-

M11 Organic farming 

M12.1 
and  M12.2 
Natura 2000 payments 

Forest-
M15 
environmental 
and 
climate  services  and 
conservation 
Source: support study on biodiversity 
Legend:  

‘+1’ (green) synergistic;  
‘0’ (blue): coherent or neutral relationship;  
‘-1’ (red): incoherent;  
‘-‘ (white): inconclusive assessment 

As pillar II measures are designed to compensate farmers for lost income and additional 
costs incurred when enrolling in the schemes relevant for biodiversity, they should have 
limited or no impact on farmers’ incomes. Some of these measures have also shown to 
deliver synergies with the objective of balanced territorial development, such as adding 
value  to  products  or  tourism,  namely  M8.5128.  AECMs,  organic  farming  and  forestry-
environment-climate measures may also indirectly support the maintenance or creation of 
new rural businesses, thereby supporting territorial development. 

The evaluation on greening found that greening measures are consistent with the wider 
CAP  objectives  of  viable  food  production  and  balanced  territorial  development. 
Regarding  viable  food  production,  there  is  a  positive/synergistic  relationship  between 

128  Slovakia  and  Germany,  in  their  M8.5  investments  for  forest  ecosystems  operations,  included  the 
creation of a tourism infrastructure, increasing the recreational value of the forest, but also benefiting 
rural growth and employment under the balanced territorial development objective of the CAP. 

74 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
                                                      
crop diversification, permanent grassland, ESPG and EFA and the objectives on market 
stability, competitiveness and enhanced income. However, the evaluation found a risk of 
contradiction  between  permanent  grassland  and  the  objectives  on  market  stability, 
competitiveness and enhanced income, where strict application of a ratio at regional level 
using authorisations impedes farmers’ economic room for manoeuvre. 

Regarding  balanced  territorial  development,  there  is  a  positive/synergistic  relationship 
between  permanent  grassland  and  ESPG  and  the  objectives  on  socioeconomic 
development.  But  there  is  the  same  risk  of  contradiction  between  permanent  grassland 
and the objective, where strict application of a ratio at regional level using authorisations 
impedes  farmers’  economic  room  for  manoeuvre.  Crop  diversification  and  EFA  were 
found to be neutral. 

5.4.  Relevance 

The extent to which CAP instruments and measures address current needs and/or new or 
emerging  issues  facing  biodiversity,  soil  and  water  is  addressed  by  comparing  the 
priorities and needs with the objectives of the CAP. The assessment is made at the level 
of the EU, Member States and farms (the latter for soil and water) and is based on replies 
to  evaluation  questions  regarding  effectiveness,  literature  review,  information  on 
Member  States  from  case  studies,  causal  analysis  (on  soil),  interviews  conducted  (with 
case  study  experts)  as  part  of  support  studies129  and  complemented  with  replies  to  the 
public  consultation  and  the  2020  Eurobarometer  survey  on  Europeans,  Agriculture  and 
the CAP130.  

The objective to address the sustainable management of natural resources remains highly 
relevant, as demonstrated in the state of the various environmental indicators assessed in 
earlier chapters. Addressing environmental (and climate) challenges is the cornerstone of 
the European Green Deal and its specific strategies on biodiversity and on farm to fork131.  

The overall relevance of the CAP with respect to environmental concerns is confirmed in 
the most recent  Eurobarometer survey. The survey shows that environmental concerns, 
including the protection of natural resources and enhancing biodiversity, have become an 
increasingly  important  priority  for  citizens.  Over  half  of  respondents  believed  that 
protecting the environment and tackling climate change (52%) should be the CAP’s main 
priority.  Roughly  7  in  10  Europeans  believe  that  the  CAP  is  contributing  to  the 
sustainable management of natural resources (70%) and the fight against climate change 
(69%).  A  large  majority  of  respondents  (92%)  were  in  favour  of  the  EU  continuing  to 
provide  subsidy  payments  to  farmers  who  carry  out  agricultural  practices  beneficial  to 
the climate and the environment. 

An  overwhelming  majority  of  respondents  to  the  public  consultation  consider  that  the 
available CAP instruments and measures are very or only somewhat relevant to respond 
to  the  actual  needs  of  sustainable  management  of  biodiversity  (75%  of  replies),  soil 

129  For  details  on  the  analysis,  see  the  reply  to  evaluation  question  14  in  the  study  on  biodiversity, 

evaluation question 12 in the study on soil and evaluation question 11 in the study on water. 

130  Special Eurobarometer 504: Europeans, Agriculture and the CAP, carried out in the 27 Member States 
of  the  European  Union  between  3  August  and  15  September  2020  among  27  237  European  citizens 
https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/cap-
glance/eurobarometer_en. 

131  See footnotes 4 to 5. 

75 

 
 
                                                      
(76%)  and  water  quality  (77%),  but  water  quantity  attracted  a  lower  rate  of  positive 
replies  (59%).  The  respondents  who  consider  the  CAP  instruments  and  measures  very 
relevant  is  lower,  between  16-20%  per  resource  (Figure  24).  At  stakeholder  level, 
business associations found the CAP instruments and measures the most relevant and EU 
citizens found them the least relevant. The other groups do not show a difference strong 
enough  between  choices  or  do  not  have  a  sufficient  number  of  respondents  to  draw 
conclusions. 

Figure 24 Relevance of the available CAP instruments and measures 

20%

20%

16%

19%

55%

57%

57%

43%

21%

3%

Biodiversity (N=177)

16%

7%

Water quality (N=178)

25%

15%

Water use (N=178)

19%

5%

Soil (N=176)

Yes, very relevant

Yes, but only somewhat relevant

Not at all

No opinion

Source: public consultation14 

On  the  basis  of  the  causal  analyses  and  assessments  of  effectiveness,  the  studies  on 
biodiversity,  soil  and  water  find  that  at  the  EU  level,  the  available  range  of  CAP 
instruments  and  measures  are  suitable  to  address  to  a  high  degree  the  needs  related  to 
biodiversity.  But  the  studies  point  to  gaps  in  the  CAP  implementation  concerning  soil 
compaction, soil biodiversity, soil salinisation132 and pesticide residues in soil, which are 
addressed by very few instruments or none at all.  

Indeed, the studies highlight that the implementation choices by Member States, notably 
on  cross-compliance  and  greening  (that  are  highly  relevant  in  addressing  sustainable 
management  issues),  play  an  important  role  in  the  actual  relevance  of  specific  CAP 
instruments  and  measures  with  respect  to  the  sustainable  management  of  natural 
resources.  However,  the  study  on  water  identified  examples  (Poland  and  Germany) 
where the needs not addressed by the CAP implementation choice of the Member State 
were covered by State aids.  

The  study  on  biodiversity  assesses  the  relevance  of  CAP  measures  in  addressing  the 
pressures  and  threats  facing  biodiversity  through  their  contribution  to  maintain  and 
restore  semi-natural  agricultural  and  forest  habitats  and  landscapes.  Accordingly,  while 
ESPG is very relevant for addressing sustainable resource objectives, it does not protect 
semi-natural  grasslands  from  all  potential  pressures,  such  as  increases  in  the  use  of 
fertiliser  or  drainage  (artificial  drainage  in  Netherlands  and  Poland).  In  a  similar  vein, 
while  EFA  measures  are  relevant,  the  majority  of  the  EFA  area  is  dominated  by  catch 
crops and nitrogen-fixing crops of low relevance to biodiversity. This shows that where 
flexibility  has  been  given  to  managing  authorities  in  the  implementation  of  EFA 
measures,  there  has  been  a  trend  towards  adopting  practises  with  little  environmental 
benefit.  The  relevance  of  pillar  II  measures  is  heightened  if  they  are  targeted  towards 

132  Due to soil salinisation measuring intrinsic issues (varies in time and space), literature is not clear in the 
number of ha affected. But it ranges between 30 million ha to more than 70 million ha affected, mainly 
across  Mediterranean  countries  and  the  Netherlands  (Soil  Salinisation  final  report,  EIP-AGRI  focus 
group, 2020). 

76 

 
 
 
                                                      
Natura  2000  sites.  In  view  of  their  effectiveness,  AECMs  (M10),  Natura  2000  (M12), 
forest investments (M8), forest-environment (M15) all help to maintain high nature value 
farmland and provide tailored interventions that respond to the needs of threatened high 
priority habitats and species. 

Overall,  AECM  (M10)  and  non-productive  investments  (M4)  are  the  most  relevant 
measures because of their ability to provide tailored interventions that can maintain and 
restore semi-natural elements in the landscape, other important habitat features and apply 
relevant  farm  management  practices,  also  regarding  soil-related  issues.  Some  particular 
actions supported under basic services and village renewal in rural areas (M7) may have 
an  indirect  effect  on  biodiversity.  Non-productive  investments  (M4)  are  relevant  in 
addressing biodiversity, water and other environmental objectives together with forestry 
measures (M8), which are used to develop Natura 2000 site management plans.  

Furthermore, rural development measures (AECMs especially) are also very relevant in 
supporting the  change from  intensive farming systems  to  reduce  fertiliser and pesticide 
inputs or retain or restore important in-field habitats (e.g. fallow lands) along with other 
landscape  features  (natural  habitats  or  hedgerows,  among  others).  The  level  of  CAP 
support  is  not  always  sufficient  to  encourage  more  farmers  into  less  intensive  farming 
methods, and a lack of knowledge/expertise can be an additional bottleneck (see 5.1.).  

Support  to  organic  farming  (M11)  is  relevant  for  biodiversity  and  soil  issues  but 
depends  on  the  various  practices  that  are  carried  out  and  their  context.  Replies  to  the 
public  consultation  on  the  organic  action  plan  indicate  a  strong  perception  of  the 
relevance of organic farming to the sustainable management of natural resources, with a 
strong majority of respondents agreeing that organic farming is beneficial to biodiversity 
(92%), the protection of the soil quality (88%), water quality (84%) and the responsible 
use of natural resources such as water (81%)133. 

The  studies  also  find  that  the  CAP  measures  on  knowledge  transfer  (M1),  advisory 
services  (M2)  and  cooperation  (M16)  can  achieve  significant  effects  by  helping  raise 
farmers’ awareness of the sustainable management of natural resources. 

The  study  on  biodiversity  also  finds  ANC  to  be  relevant  for  the  maintenance  of  semi-
natural  habitats,  just  as  it  finds  the  basic/single  area  payment  schemes  and  voluntary 
coupled  support  to  be  relevant  in  some  circumstances  (for  example,  in  the  Netherlands 
where  it  is  supporting  required  livestock  grazing  in  dunes,  heaths  and  saltmarshes). 
Nevertheless,  their  relevance  (ANC,  voluntary  coupled  support,  BPS/SAPS)  is  less,  as 
they  do  not  necessarily  have  environmental  conditions  that  protect  the  habitat  from 
damaging  agricultural  and  forest  activities  (as  cross-compliance  requirements  are  not 
sufficient to achieve this). 

The mid-term review of the Biodiversity Strategy concluded that the CAP design is fit for 
its  objectives:  the  CAP  reform  for  2014-2020  provides  a  range  of  instruments  that  can 
help to support biodiversity. 

133  Public Consultation on the Action Plan for the development of the organic sector, conducted between 

4 September 2020 and 27 November 2020, with 841 replies received. 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12555-Organic-farming-action-
plan-for-the-development-of-EU-org/public-consultation. 

77 

 
 
                                                      
5.5.  EU Added Value  

The  extent  to  which  the  CAP  instruments  and  measures  provided  added  value  for 
biodiversity  and  landscapes,  soil  quality  and  water,  as  compared  to  national  and/or 
regional support from Member States was assessed against a hypothetical counterfactual 
without EU-funded direct payments and no EU co-financed rural development measures. 
The assessment was based on qualitative analysis, including a review of the presence or 
absence of EU  and national  regulations,  of non-CAP  related measures and strategies, a 
review  of  operations  taken  outside  the  framework  of  the  CAP  in  EU  and  non-EU 
countries,  stakeholder  interviews  in  case  study  Member  States  (managing  authorities, 
farm advisors, farmer representatives, experts) and literature review.  

Given the commonality of findings  on EU added value for biodiversity, soil and water, 
the assessment is structured according to  the results of the  analysis combining analysis 
from the three evaluation support studies and the replies to relevant evaluation questions 
in these studies134. 

General considerations 

Economic  drivers  such  as  improving  the  competitiveness  of  agriculture,  and/or 
maintaining  the  viability  of  farming  in  remote  rural  areas,  as  well  as  financial  and 
administrative simplification were strong drivers of implementation choices by Member 
States.  By  contrast,  the  counterfactual  scenario  depicts  a  lower  ambition  by  Member 
States to use agricultural support for delivering biodiversity ambitions in the absence of 
the  CAP.  However,  as  national  and  EU-funded  projects  are  often  linked  via  integrated 
approaches,  it  is  difficult  to  make  a  strict  comparison  between  the  effectiveness  and 
efficiency of national projects and similar CAP-supported projects135. National initiatives 
are  sometimes  coordinated  with  the  CAP  to  support  larger  scale  projects  requiring 
significant financial capacities, while smaller scale projects may be supported locally to 
lower administrative burden.  

Broad findings 

On the basis of the  assessment  of effectiveness,  the evaluation shows that  certain  CAP 
instruments and measures have provided added value at EU level in terms of the scale of 
benefits compared to what individual Member States might have done in the absence of 
the CAP and equivalent obligations. The evaluation found that:  

  Cross-compliance  sets  a  baseline  for  protection  of  biodiversity,  soil  and  water,  on 

84% of EU utilised agriculture area (UAA). 

  The  EFA  measure  and,  to  a  more  limited  extent,  the  crop  diversification  measure 
helped stem the decline of fallow in many Member States and stimulated increases 
in others.  

  The AECM (M10) helped to reduce the intensity of management on crop and arable 

land and to maintain extensive pastoral systems and landscape features.  

 

Several  other  pillar  II  measures  are  making  significant  contributions  to  the 
conservation of biodiversity and landscapes, especially in high nature value farming 

134  Biodiversity study question 15, soil study question 15 and water study question 14. 
135  National initiatives are sometimes coordinated with the CAP to support larger scale projects requiring 
significant  financial  capacities,  while  smaller  scale  projects  may  be  supported  locally  to  lower 
administrative burden. For examples, see table 32 in the support study on soil. 

78 

 
 
                                                      
areas and other semi-natural habitats, but it is not possible to reliably estimate their 
net combined impact.  

  Among  other  things,  the  pillar  II  measures  promoted  improved  management  of 
fertilisers  and  pesticides  (Priority  4  to  restore  and  preserve  ecosystems  related  to 
agriculture)  and  increased  efficiency  in  water  use  by  agriculture  (Priority  5  on 
promoting resource efficiency).  

  The  ‘soft’  measures  (M1,  M2,  M16)  provide  significant  added  value  to  support 

integrated approaches based on farmers’ training. 

A significant share of respondents (46% of 183 replies) to the public consultation found 
that the relevant applicable CAP instruments and measures create EU added value ‘to a 
large  extent’  (37%)  or  ‘to  a  very  large  extent’  (9%)  with  respect  to  the  sustainable 
management of natural resources. On the other hand, 31% of the respondents answered 
that  there  is  EU  added  value  ‘to  some  extent’,  13%  ‘to  a  very  small  extent’  and  6% 
responded ‘not at all’. The remaining 4% did not have an opinion. 

Joint  management  of  transboundary  resources  creating  legal  certainty  and  level 
playing field 

Increased  effectiveness  at  EU  level  could  occur  where  CAP  measures  have  supported 
transboundary  action,  for  example  where  AECM  schemes  are  linked  to  Member  State 
implementation  of  other  EU  policies,  for  example  through  conversion  of  arable  to 
permanent  grassland  or  afforestation  in  ‘shared’  catchments,  or  action  on  migratory 
species. 

As  water  requires  transboundary  management,  joint  actions  are  necessary  to  ensure  a 
certain consistency (e.g. to avoid water pollution from a Member State located upstream 
which would impact a Member State located downstream). As a whole, the  opinions of 
the stakeholders in the case studies agree that common action is relevant to address water 
issues on a broader scale, and especially in the case of cross-border catchments (e.g. the 
Rhine in France and the Netherlands, the Danube in Austria, Croatia, Romania, etc.).  

Setting  up  common  objectives  and  a  common  legal  framework  (e.g.  on  water  status) 
ensures  fairness  between  Member  States  and  is  relevant  in  tackling  environmental 
(including  water)  objectives.  Case  study  interviews  confirmed  the  importance  of  joint 
action  at  EU  level  to  ensure  a  common  objective  and  framework  on  environmental 
issues, including water protection. The CAP makes for a level playing field and prevents 
any  competition  across  the  Member  States  that  may  lead  to  a  race  to  the  bottom  for 
environmental actions.  Member States have the choice of increasing their environmental 
ambitions through their implementation choices. 

Higher level of ambition for the management of natural resources 

The  strong  focus  of  Member  State  implementation  choices  to  address  economic 
objectives implies that in the absence of the CAP, Member States’ underlying ambition 
to  use  agricultural  support  payments  to  deliver  biodiversity  ambitions  could  be  quite 
low.  From  the  literature  review,  from  the  findings  of  previous  analysis  and  from  case 
study  interviews,  it  appears  that  the  EU  framework  brought,  to  some  extent,  a  certain 
added  value  to  the  process  of  tackling  water  issues  via  agriculture  at  the  EU  level. 
According  to  the  literature  reviewed,  the  management  of  agricultural  soils  in  the  EU 
Member  States  remains  mainly  influenced  by  the  CAP  and  its  implementation  by  the 

79 

 
 
Member States. Indeed, few Member States have a comprehensive national soil policy136, 
and sustainable soil management appears to  be in  most cases an outcome derived from 
policies  focusing  on  other  environmental  issues  (water,  biodiversity,  peatlands,  etc.). 
Thus, in most Member States, the CAP provides EU added value by increasing the level 
of  ambition  for  biodiversity  and  sustainable  soil  management,  by  raising  awareness  on 
water issues and by providing the corresponding means for action (budget and measures). 

The  Member  States’  choices  of  rural  development  programmes  reveal  the  general  low 
level  of  ambition  of  local  authorities  to  tackle  issues  related  to  soil  quality.  Moreover, 
results from an online survey of European soil experts and practitioners concluded that, 
without  some  key  EU  policies  including  the  CAP,  the  ambition  for  soil  management 
would  be  weaker  among  the  13  Member  States  studied  (Frelih-Larsen  et  al.,  2017). 
Interviews in the case study areas confirm this opinion as predominant in 6 out of the 10 
case  studies  (Belgium-Wallonia,  Bulgaria,  Czechia,  Greece,  Spain-Aragon,  Italy-
Tuscany).  On  the  contrary,  the  general  opinion  from  Denmark,  Ireland  and  Sweden  is 
that the level of ambition would be the same. This hypothetical status quo is based on the 
fact  that  actions  are  already  taken  outside  the  framework  of  the  CAP  (e.g.  Denmark 
protects  its  aquatic  environment  against  nitrates;  Swedish  national  regulations  were 
already promoting catch crops and practices preventing phosphorus leaching).  

In  some  Member  States  (e.g.  Germany,  Spain,  Croatia,  Italy,  Poland,  Romania  and 
Finland),  the  CAP  framework  has  stimulated  a  higher  level  of  requirements  and/or 
budget for water and environmental issues than would have been done nationally (e.g. by 
fostering  the  development  of  advisory  services  in  Romania,  strengthening  the  level  of 
verifying compulsory measures, supporting changes of practices, etc.).  

Minimum level of financial support 

The funding rules for the CAP have required Member States to use 30% of their direct 
payment allocation for pillar 1 greening measures and 30% of their EAFRD budget for 
specific  environmental  and  climate  measures.  EAFRD  funding  also  provided 
opportunities  for  synergy  between  EAFRD  and  other  EU  funds,  notably  the  LIFE 
programme106. These elements, together with the compulsory use of AECM have led to 
higher  financial  allocations  for  addressing  biodiversity,  soil  and  water  objectives  than 
would be the case in the absence of the CAP.  

It  was  confirmed  by  the  representatives  of  local  authorities  interviewed  (Bulgaria, 
Czechia,  Greece,  Spain-Aragon,  Italy-Tuscany)  that  the  budget  allocated  to  tackle  soil 
issues,  in  areas  where  reduced  ambition  was  planned,  would  have  been  lower  in  the 
absence  of  the  CAP.  This  was  also  the  case  in  Germany-Bavaria  and  Sweden:  though 
significant ambitions for soil protection were set at the local level, the CAP framework 
enforced  the  allocation  of  financial  means  to  encourage  the  implementation  of 
sustainable practices. 

136  Few Member States have an overarching soil protection policy (e.g. the Soil Act in Bulgaria at national 
level or the Bavarian Soil Protection Act at regional level). Likewise, not all soil threats are addressed 
with the same level of requirements and, when addressed, sustainable soil management appears to be in 
most  cases  an  outcome  derived  from  policies  and  legislation  focusing  on  other  environmental  issues 
(water,  biodiversity,  peatlands,  desertification,  etc.).  In  addition,  national  strategies  directly  targeting 
soil issues are not always allocated the means for concrete intervention (e.g. according to a researcher 
in Spain, the Spanish national programme to combat desertification dating back to 2008 has not been 
allocated a budget for actions). 

80 

 
 
                                                      
Knowledge sharing 

EU-level  knowledge-sharing  such  as  that  through  the  European  Network  for  Regional 
Development Contact Point and EIP-AGRI has also added value to what Member States 
could have achieved at national level. Arrangements to share knowledge at EU level, for 
example through the ENRD Contact Point and the EIP-AGRI also have the potential to 
improve  the  effectiveness  of  rural  development  programme  actions  to  a  greater  extent 
than would be the case were Member States to make their own arrangements.  

Coordination within or between regions and Member States for soil issues, through CAP 
measures and instruments (including knowledge sharing), remains limited. The absence 
of  a  legally  binding  framework  that  clearly  determines  soil  threats  and  monitoring 
indicators  is  an  obstacle  to  better  coordination  and  gains  in  effectiveness137.  So  far,  the 
CAP  has  enabled  gains  in  technical  cooperation  among  European  stakeholders  (e.g. 
farmers, scientists, etc.) on specific soil issues through research programmes for instance. 
But  no  case  study  has  underlined  an  effect  on  cooperation  between  government  and 
regions.  However, EU-funded projects  via  LIFE and Horizon 2020, such as Re-Care or 
Soilcare, have helped to improve exchanges between Member States (Denmark, Greece).  

According  to  interviewees  in  the  case  study  Member  States,  the  EU  level  brought 
additional  added  value  by  ensuring  coherence  between  the  CAP  and  the  Water 
Framework  Directive  objectives  and,  to  a  certain  extent,  by  promoting  exchanges 
between  Member  States  on  water  (e.g.  through  EIP  projects  and  ENRD).  This  latter 
aspect  could  probably  be  improved,  and  the  CAP  could  promote  more  interaction  and 
knowledge transfer between Member States.  

6.  CONCLUSIONS 

The purpose of this evaluation was to assess the impact of relevant CAP instruments and 
measures on biodiversity, soil and water and the extent to which the policy instruments 
of  the  2014-2020  CAP  have  helped  achieve  the  general  objective  of  sustainably 
managing  natural  resources138.  The  measures  covered  by  the  evaluation  study  are  the 
relevant  instruments  set  out  in  the  basic  regulations  of  the  2014-2020  CAP,  i.e.  the 
Regulations on Direct Payments, Rural Development, the Common Market Organisation, 
and the Horizontal Regulation139. The geographical scope is the EU-28, including the UK. 

The evaluation is primarily based on the external support studies on biodiversity140, soil141 
and  water142  and  the  responses  to  the  corresponding  public  consultation143,  which  are 

137  According  to  recent  studies,  one  of  the  main  obstacles  to  coordination  among  authorities  in  Member 
States is the lack of an explicit definition of soil and soil threats (Paleari,  2017; Ronchi et al., 2019). 
Without a common definition of soil-related terms established at EU level, there is a risk of inconsistent 
implementation of EU soil provisions across the EU. This current situation motivated Member States to 
act independently, adopting and implementing sectoral policies and strategies. 

138  Complementing the evaluations of the greening and forestry measures of the CAP and the evaluation of 

the CAP’s performance in achieving the objectives on ‘climate action’. 

139  Regulations (EU) No 1307/2013, No 1305/2013, No 1308/2013 and No 1306/2013. 
140  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

policy/cmef/sustainability/impact-cap-habitats-landscapes-biodiversity_en. 

141  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

policy/cmef/sustainability/impact-cap-sustainable-management-soil_en. 

142  https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

policy/cmef/sustainability/impact-cap-water_en. 

81 

 
 
                                                      
complemented by analysis and data from various sources, including relevant evaluations. 
The  methodological  approach  combines  empirical  methods  (statistical  analysis)  with 
qualitative analysis (case studies, interviews and literature review).  

The evaluation is constrained by the lack of sufficient and timely data (limiting a robust 
quantitative analysis), the very short observation period which only offers a narrow view 
of slower and longer-term environmental processes and the abundance of external factors 
affecting natural resources (e.g. urban sprawl, economic development, climate change).  

The short observation period limits the potential of doing a robust analysis of the CAP’s 
impact  on  the  sustainable  management  of  nature  resources,  especially  considering  that 
natural  processes  are  lengthy  and  impacts  materialise  over  longer  periods.  As  such, 
merely looking at the available indicators during the observation period is insufficient to 
draw meaningful conclusions. An additional difficulty in arriving at a comprehensive and 
conclusive judgement on the impact of the 2014-2020 CAP instruments and measures on 
the  sustainable  management  of  natural  resources  stems  from 
the  variety  of 
implementation choices made by individual Member States. 

The evaluation is particularly relevant in light of the objectives of the EU biodiversity144 
and  farm  to  fork145  strategies,  which  complement  the  European  Green  Deal146.  The 
increased  emphasis  on  agro-environmental  targets,  combined  with  the  need  for  a 
resilient, safe and sustainable food system ensuring food security, results in a demand to 
improve the balance between farming and nature. The sustainable management of natural 
resources remains a key CAP objective147. 

6.1.  Effectiveness 

The CAP  provides  an extensive ‘baseline protection’ with  84% of the total  EU utilised 
agriculture  area  (UAA)  subject  to  mandatory  cross-compliance.  Greening  obligations 
provide  additional  environmental  protection  covering  80%  of  UAA,  and  voluntary 
commitments  under  pillar  II  add  more  targeted  environmental  provisions  on  15%  of 
UAA  for  AECM  measures  and  on  5%  of  UAA  supporting  organic  farming.  The  area 
subject to sustainable management commitments increased over the period evaluated. 

Effectiveness of CAP instruments/measures 

Regarding  cross-compliance, GAECs have  a key  role in  helping  to  maintain landscape 
elements (in particular buffer strips, grassed strips and terraces) and reduce soil erosion 
(GAECs  4  and  5).  They  also  contribute  to  practices  limiting  the  loss  of  soil  organic 
matter (GAEC 4). However, GAECs 4, 5 and 6, which specifically target sustainable soil 
management,  while  often  ensuring  that  the  situation  does  not  deteriorate  further,  could 

143  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1951-Evaluation-of-the-impact-

of-the-CAP-on-water/public-consultation. 

144  https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/actions-being-taken-eu/EU-

biodiversity-strategy-2030_en. 

145  https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/actions-being-taken-

eu/farm-fork_en. 

146  https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en. 
147  Three  of  the  nine  key  objectives  of  the  European  Commission  proposal  on  the  CAP  for  2021-2027 
address  the  environment  and  climate,  notably  environmental  care,  the  preservation  of  landscapes  and 
biodiversity,  and  climate  change  action.  For  more  information,  visit:  https://ec.europa.eu/info/food-
farming-fisheries/key-policies/common-agricultural-policy/future-cap/key-policy-objectives-future-
cap_en. 

82 

 
 
                                                                                                                                                              
have  brought  more  beneficial  effects  at  EU  level,  by  triggering  more  changes  of 
practices.  Other  GAECs  and  SMRs  could  have  indirect  positive  effects  on  waterbodies 
by improving the capacity of soil to retain water, limiting erosion or maintaining specific 
land  covers  beneficial  for  water.  But  the  study  on  soil  reveals  that  case  study  Member 
States usually settled for minimum standards. 

With  respect  to  greening  measures,  ESPG  plays  an  important  role  in  preventing  the 
ploughing  of  designated  semi-natural  permanent  grassland  habitats  (as  well  as  other 
wetlands and carbon rich soils which are often of high value for biodiversity). The ban on 
ploughing all ESPG and the permanent grasslands of Member States was paramount  in 
taking  action  on  carbon  storage  and  erosion  on  those  areas.  Although  the  ban’s  added 
value  in  Natura 2000  sites  is  uncertain,  given  the  protection  already  afforded  by  the 
Nature Directives, it is likely to bolster protection, given the evidence of ongoing losses 
of permanent grassland within the Natura 2000 network. The ban also has the potential to 
protect  ESPG  outside  the  Natura 2000  network,  where  the  rate  of  loss  of  semi-natural 
grassland is especially high. Therefore it complements the Nature Directives. However, 
this potential is not realised due to the very low number of sites outside Natura 2000 sites 
with the ESPG designation.  

Certain  EFA  elements,  particularly  fallow  land,  multiannual-fodder  crops  (e.g.  alfalfa) 
and  landscape  features  (e.g.  hedgerows,  trees  and  ponds)  benefit  biodiversity  in  arable 
landscapes. However, the potential benefits of the EFA measure are not fully realised, as 
the most commonly declared EFA elements  (i.e. catch crops and nitrogen-fixing crops) 
have low biodiversity benefits for most farmland species, other than soil fauna. However, 
they  can  reduce  water  pollution  and  in  so  doing  benefit  aquatic  ecosystems  and 
biodiversity. They can also contribute to practices limiting the loss of soil organic matter 
and help foster activities improving soil biodiversity and reducing soil pollution through 
restrictions on plant protection products. 

The crop diversification requirement was one of the key CAP instruments targeting soil 
quality. However, it had effects at EU level mainly on a small percentage of land, but on 
the  most  intensive  areas.  Furthermore,  in  certain  situations,  crop  rotation  could  have 
yielded  more  environmental  benefits  than  crop  diversification.  Nevertheless,  positive 
effects were observed in some Member States (e.g. reduction of monoculture in Spain). 

AECM (M10) and Natura 2000 (M12) are the most effective CAP measures addressing 
biodiversity  objectives,  particularly  the  tailored  and  targeted  higher  level  AECM 
schemes.  However,  the  impacts  of  AECM  schemes  are  often  constrained  by  limited 
budgets and farmer uptake, and the Natura 2000 measure has been infrequently used by 
Member  States  (despite  a  45.5%  increase  in  the  areas  supported  under  M12).  Organic 
farming  (M11)  provides  biodiversity  benefits,  particularly  where  it  occurs  in  more 
intensively  farmed  landscapes,  as  it  contributes  to  practices  limiting  the  loss  of  soil 
organic  matter  and  fosters  activities  positive  on  soil  biodiversity  and  soil  pollution 
through restrictions on the type of plant protection products and fertilisers. 

Investment  support  (M4)  under  focus  area  5A  for  increased  efficiency  in  water  use  is 
beneficial for water abstraction and use148. An assessment was impossible due to the case 

148  However,  there  are  mixed  perceptions,  with  environmental  experts  claiming  that  insufficient 
compliance  controls  and  monitoring  hinder  its  effectiveness.  Nevertheless,  as  water  basin  authorities 
are responsible for irrigation authorisations and monitoring water use, these possible drawbacks are not 
due to the CAP itself. 

83 

 
 
                                                      
studies  chosen.  It  is  particularly  difficult  to  determine  to  what  extent  the  CAP 
instruments  and  measures  helped  to  address  biodiversity,  habitats  and  landscape 
objectives  in  forest  areas.  Evidence  of  the  biodiversity  impacts  of  the  forest  measures 
(M8  and  M15)  and  the  afforestation  and  agroforestry  elements  of  the  EFA  is  lacking. 
However,  these  measures  are  not  frequently  used  by  Member  States;  and  the  pillar  II 
measures are only targeted at very high biodiversity areas in a very few cases in the case 
study Member States. Therefore it is likely that they are having limited overall impacts, 
although locally these may be more significant.  

ANC payments do not intrinsically contribute to environmental objectives. But they are 
likely to contribute to the household income of farming systems with a high nature value 
and  thus  contribute  to  the  continued  agricultural  use  of  semi-natural  habitats  in 
Natura 2000 sites, as there is a high level of overlap between the areas.  

With  the  exception  of  ANC  payments,  direct  payments  (including  voluntary  coupled 
support) may also maintain beneficial farming activities over wider areas. But they may 
also facilitate agricultural improvements and intensification. The impact on biodiversity 
resulting from this can be detrimental, unless it is limited through appropriate eligibility 
conditions that benefit environmental objectives. 

Effectiveness of relevant CAP instruments/measures per topic 

The  overall  contribution  of  the  relevant  CAP  instruments  and  measures  to  biodiversity 
and  landscapes  is  difficult  to  estimate  due  to  the  lack  of  sufficient  data  (notably  field 
level  indicators),  different  implementation  choices  by  Member  States  and  numerous 
external  factors  driving  biodiversity  change.  But  the  available  CMEF  indicators  do  not 
point to particular improvements at the EU level over the (very short) observation period. 

Regarding  relevant  CAP  instruments  and  measures  on  soil-relevant  management 
practices,  provisions  on  the  use  of  plant  protection  products  and  fertilisers  are  highly 
relevant  and  concern  a  significant  share  of  EU  arable  land.  These  provisions  include 
cross-compliance,  which  sanctions  beneficiaries  when  not  complying  with  the  relevant 
rules and helps to ensure compliance with the rules for animal fertiliser application to soil 
in  nitrate  vulnerable  zones.  The  provisions  also  cover  the  ban  on  plant  protection 
products on EFAs and support for organic farming.  

The CAP has contributed to durable changes in farmers’ practices by helping introduce 
the use of catch, cover and nitrogen-fixing crops. AECM contributes to practices limiting 
the loss of soil organic matter and encourages activities positive to soil biodiversity and 
soil  pollution.  AECM  (M10)  supported  reduced  tillage  on  arable  land,  but  this  was 
limited  to  specific  areas  and  therefore  did  not  lead  to  significant  coverage  at  EU  level. 
There  were  also  limited  effects  on  the  maintenance  of  crop  residues,  manuring  and 
compost application. 

Given the limited observation period and lack of sufficient data, it was not possible to do 
a robust assessment of the impact of the relevant CAP instruments and measures on soil 
organic  matter,  soil  biodiversity  and  soil  pollution,  and  on  changes  in  soil  nutrient 
balance. The same holds for soil compaction and salinisation, for which the CAP does 
not provide a targeted instrument or measure, and so its impact would be very limited by 
default.  

The most relevant CAP instruments and measures for the sustainable management of 
water  include  cross-compliance,  which  strengthens  the  controls  of  requirements 
established  outside  the  CAP  (such  as  the  Nitrates  Directive)  and  sets  minimum 

84 

 
 
mandatory  standards  for  the  good  agricultural  and  environmental  condition  of  land-
targeting  water  (notably  buffer  strips,  authorisation  for  water  abstraction  in  case  of 
irrigation,  prohibition  of  discharging  listed  dangerous  substances).  Whereas  cross-
compliance provides a very basic level of protection, AECM (M10) and organic farming 
(M11)  are  the  most  effective  pillar  II  measures  to  reduce  agricultural  pressures 
essentially on water quality. According to the CMEF result indicators, the percentage of 
irrigated land switching to more efficient irrigation systems was very limited at the EU 
level, and it is not possible to  demonstrate the overall impact  of irrigation measures on 
water use.  

The limitations of available data make it difficult  to  assess the effects  of relevant  CAP 
instruments and measures on the water-holding capacity of soil or on the improvement 
of waterbodies status. Soil and climatic conditions highly influence the effectiveness of 
the  instruments  and  measures,  and  economic  factors  play  a  significant  role  in  inducing 
farmers to implement specific agricultural practices or produce specific crops beneficial 
to water-related objectives. 

With  respect  to  land  use  and  management,  the  CAP  helps  to  maintain  particular  land 
uses through various instruments and measures. CAP support is necessary to  encourage 
non-profitable practices and land-use and to prevent the decrease of traditional practices 
beneficial  for  soil  protection.  The  ESPG  measure  bans  the  ploughing  of  designated 
grassland and protects just under one third of permanent grassland in Natura 2000 areas 
and  1%  of  permanent  grassland  outside  Natura  2000  areas.  The  EFA  and,  to  a  more 
limited  extent,  the  crop  diversification  measure  have  helped  stem  the  decline  of  fallow 
land  in  many  Member  States  and  stimulated  increases  in  others.  Direct  payments  in 
general  (including  basic  payments,  greening, voluntary  coupled support and ANC) may 
have,  to  some  extent,  supported  continued  agricultural  activity  on  semi-natural  habitats 
that are at risk of abandonment.  

AECM  has  supported  extensive  arable  and  grassland  systems  on  8.9  million  hectares 
(11.6%  of  the  area  estimated  to  be  of  high  nature  value)  and  contributed  to  the 
maintenance and creation of landscape features, with 2.24 million hectares of ecological 
features  under  agreement  by  2017  (field  margins,  buffer  areas,  flower  strips  alongside 
hedgerows and trees). The AECM is also used to support less intensive management on 
permanent crop and arable land through reduced inputs (5% of such land), soil cover and 
soil  management 
techniques  (2.8%)  and  feed  and  manure  management  (1%). 
Afforestation  and  the  establishment  of  agroforestry  systems  were  fostered  by  voluntary 
measures  only  and  implemented  to  a  limited  extent,  in  coherence  with  the  change  they 
involve in land use. 

6.2.  Efficiency 

The efficiency of relevant CAP instruments and measures was limited by implementation 
choices.  Member  States  could  have  allocated  more  of  their  funding  to  the  measures 
which  deliver  benefits  for  biodiversity  most  effectively  (AECMs,  Natura 2000  and 
conversion to organic farming), rather than less effective ones (e.g. ANC).  

Soil-oriented AECMs can have more specific effects on soil quality for a lower cost/ha 
than  support  for  organic  farming.  But  the  payment  rates  of  AECMs  were  not  always 
sufficient  to  motivate  farmers  to  commit  to  the  implementation  of  the  supported  soil-
relevant  activities.  In  some  Member  States,  the  calculation  of  the  payment  rate  of 
AECMs (M10) fails to ensure sufficient uptake, in particular by highly productive farms. 

85 

 
 
On  the  other  hand,  payment  rates  under  support  for  activities  in  forests  (M8),  organic 
farming  (M11),  and  the  environmental  measures  of  fruits  and  vegetables  operational 
programmes (CMO Regulation) were generally found to be set at an appropriate level to 
encourage  application  by  farmers  and  forest  holders  in  Member  States  covered  by  the 
case studies.  

For organic farming (M11) in particular, payment rates can be considered efficient, given 
that  organic  farming  greatly  reduces  the  risks  of  water  pollution  from  fertilisers  and 
pesticides  and  its  associated  depollution  costs.  On  the  other  hand,  investments  (M4) 
targeting  water-relevant  operations  were  not  found  to  be  very  efficient  for  protecting 
water from pollution.  

The  ratio  between  distributed  payments  and  the  observed  benefits  of  the  crop 
diversification  measure  is  considered  low,  mostly  because  it  did  not  lead  to  significant 
changes in agricultural practices beneficial for sustainable soil management.  

The  CAP  instruments  and  measures  with  the  greatest  benefits  for  biodiversity  and  soil 
(notably  AECM  (M10))  are  also  those  with  the  greatest  administrative  cost,  but  that  is 
considered  overall  as  proportionate,  given  the  inherent  complexity  of  some  of  the 
management practices requiring support.  

Administrations  and  farmers  found  support  for  organic  farming  (M11)  less  difficult  to 
manage  than  AECM.  Forest-environment  and  climate  services  (M15)  and  afforestation 
(M8)  were  both  significant  measures  fostering  land  covers  beneficial  for  water 
protection.  However,  they  generate  a  heavy  administrative  burden.  Investments  (M4) 
generated  a  heavy  administrative  burden,  and  the  beneficiaries  also  mentioned 
cooperation (M16) as being burdensome. 

Greening  measures  and  cross-compliance  effectively  helped  to  maintain  specific 
practices  beneficial  for  water  protection.  The  administrative  costs  associated  with  the 
verifications  of  cross-compliance  and  greening  measures  are  included  in  the  general 
management  system  of  the  CAP  (the  Integrated  Administration  and  Control  System-
IACS). The cost of IACS is significant but deemed as necessary in view of the benefits 
obtained. Regarding the soil-related GAECs, controllability and easy management have 
been a major concern for administrations, because of the high costs associated with these 
controls  and  the  high  financial  risks  for  farmers  in  case  of  non-compliance.  Some 
Member  States  increased  the  administrative  complexity  for  themselves  by  deciding  to 
give farmers EFA options which were already covered by cross-compliance standards for 
the good agricultural and environmental condition of land (GAEC).  

6.3.  Coherence 

The internal coherence of the CAP instruments and measures to support the sustainable 
management  of  biodiversity,  soil  and  water  is  considerable;  and  there  are  numerous 
opportunities for measures to be combined in ways which are synergetic. This is the case, 
for  example,  with  support  for  the  AECMs  (M10),  the  organic  farming  measure  (M11), 
the Natura 2000 measure (M12) and non-productive investments (M4). All of these can 
be  used  together  and  can  also  benefit  from  the  support  for  knowledge  transfer  (M1), 
advisory  services  (M2)  and  cooperation  (M16),  as  well  as  the  farm  advisory  system. 
Voluntary  coupled  support  for  nitrogen-fixing  crops  and  animal  husbandry  (which 
contributes  indirectly  to  the  maintenance  of  grassland  and  promotion  of  the  use  of 
manure under allowed limits) may indirectly have a positive effect on soil management.  

However, a number of potential inconsistencies were identified:  

86 

 
 
  overlap between the greening requirement to declare EFA and the baseline set by 

cross-compliance for catch crops on nitrogen-vulnerable zones;  

 

risk that ANC support, direct payments and voluntary coupled support may lead 
to agricultural intensification with detrimental impacts on biodiversity;  

  exemption  of  farmers  participating  in  the  small  farmers  scheme  and  permanent 

cropland from all greening requirements; 

 

irrigation support, as it is difficult to guarantee that the supported investment will 
not  lead  to  increased  pressure  on  water  resources,  especially  in  cases  where  the 
irrigated area increases;  

  sector-specific support granted under the Regulation for the common organisation 
of the markets can be used to support investment in irrigation under less stringent 
rules than investments (M4);  

  sectors with the highest impact on water quality and quantity (e.g. fruits, flowers, 
wine)  are  not  always  eligible  for  direct  payments  and  thus  not  subject  to 
corresponding greening and GAEC requirements. 

CAP instruments and measures are mostly coherent with other related EU and national 
policies  relevant  for  biodiversity,  soil  and  water,  with  a  number  of  EU  environmental 
policies strongly linked with the CAP through statutory management requirements (e.g. 
the Water Framework Directive, the Nitrates Directive, the Sustainable Use of Pesticides 
Directive).   

However,  had  Member  States  made  different  implementation  choices  and  had  they 
always used the most effective and efficient measures, the CAP could now in practice be 
delivering greater synergies with the EU’s biodiversity strategy to 2020, in particular the 
implementation of the Birds and Habitats Directives and Natura 2000 network.  

Inconsistencies can also arise in cases where CAP support is granted to increase irrigated 
areas  where  waterbodies  with  less  than  good  quantitative  status  are  affected.  Granting 
direct  payments  to  specific  sectors  with  mixed  effects  on  water,  depending  on  their 
agricultural  practices,  prevents  full  coherence  of  the  CAP  with  EU  water  policy.  Also, 
specific sectors with a potential impact on water quality and quantity are not constrained 
by  the  water-relevant  CAP  instruments  and  measures  in  all  Member  States  (i.e.  cross-
compliance, GAEC and the greening measures). 

6.4.  Relevance 

Throughout  the  observation  period,  the  CAP  has  been  of  important  relevance  in 
addressing the sustainable management of natural resources. Overall, the CAP has had a 
positive effect, in a situation where available context indicators pointed toward continued 
pressure on biodiversity, soil and water resources.  

The  relevance  of  CAP  instruments  and  measures  are  established  from  the  findings  on 
effectiveness, efficiency and coherence. Overall, there is no single instrument or measure 
that  can  be  qualified  as  the  most  relevant  for  addressing  the  objective  of  sustainable 
management of natural resources: cross-compliance measures, support to AECMs (M10) 
and  organic  farming  (M11)  appear  to  be  beneficial  across  the  evaluated  areas.  As 
mentioned  before,  the  implementation  choices  of  Member  States  greatly  determine  the 
effects of the instruments and measures.  

The analysis identifies particular challenges that the CAP does not address sufficiently or 
at all in a relevant manner: 

87 

 
 
  Soil compaction, soil biodiversity and pollution lack targeted measures. 

  Crop diversification did not sufficiently induce the implementation of diversified 

crop rotations beneficial to soil quality. 

  The  CAP  was  unable  to  provide  farmers  a  specific  safety  net  to  encourage  risk 

taking when switching to conservation farming practices. 

  Specific  measures  are  lacking  to  target  the  use  of  pharmaceutical  products  or 

cleaning products in the livestock sector (regarding water quality). 

  Help was lacking for irrigated farms to adapt to water scarcity stress episodes, by 
supporting their diversification with rain fed crops in areas prone to droughts. 

The  water-related  needs  not  covered  by  the  CAP  are  sometimes  addressed  through 
national policies.  

6.5.  EU added value 

Overall,  the  CAP  instruments  and  measures,  particularly  those  programmed  under  the 
EAFRD, provide EU added value to biodiversity and landscapes, soil and water. They do 
this  chiefly  by  setting  a  higher  level  of  ambition  and  requiring  minimum  levels  of 
financial  support  to  be  allocated  to  these  objectives  than  would  likely  be  the  case  if 
Member States were left to design national measures themselves (given their preference 
for financial/economic priorities149). This means Member States have to use 30% of their 
direct  payment  allocation  for  pillar  I  and  30%  of  their  EAFRD  budget  for  specific 
environmental and climate measures, which might not be the case without the CAP.  

EU added value is also created by treating these natural resources on an EU level, as 
water resources, biodiversity and soil transverse borders and are a shared responsibility. 
Natural  resources  require  transboundary  management  and  joint  actions  to  ensure 
consistency,  which  the  EU  provides.  A  joint  action  at  EU  level  also  creates  a  level 
playing field for all Member States, provided that the system of controls and sanctions at 
Member State level do not lead to distortions. 

The CAP also gives Member States legal certainty on objectives and the availability of 
funding availabilities for natural resources for the duration of the programming period. 

The EU-level networking and knowledge sharing funded by the CAP also deliver EU 
added value by helping to improve the CAP’s effectiveness in delivering its objectives. 
European Innovation Partnership for Agriculture groups and European Network for Rural 
Development  focus  groups have encouraged coordination  among European researchers, 
civil  society,  companies  at  EU  level.  However,  the  CAP  has  brought  little  gains  in 
coordination between authorities of the EU Member States and regions, with one of the 
main  obstacles  for  coordination  among  Member  States  being  the  lack  of  common 
definitions of soil quality and soil threats. 

6.6.  Lessons learned 

The  presence  of  the  CAP  has  raised  Member  States’  ambition  to  address  sustainable 
resource management objectives and their level of funding, creating EU added value. 

149  Economic  drivers  such  as  improving  the  competitiveness  of  agriculture,  maintaining  the  viability  of 
farming  in  remote  rural  areas  and  financial  and  administrative  simplification  strongly  influenced  the 
implementation choices by Member States. 

88 

 
 
                                                      
There is room for Member States and regions to improve their implementation choices, 
so that they better reflect environmental objectives and the design of policy measures and 
ultimately  ensure  effective,  efficient  and  coherent  outcomes.  With  respect  to  particular 
instruments and measures: 

  Member  States  have  not  made  sufficient  use  of  the  available  CAP  instruments 

and measures to protect semi-natural features, in particular grassland. 

  The  design  and  funding  of  AECM  support  has  been  insufficiently  attractive  to 
bring  about  the  changes  in  management  necessary  to  improve  their  biodiversity 
performance, especially for intensive cropping farms. 

  Member States could have used a wider range of CAP instruments and measures 

to support the co-existence of agriculture with biodiversity. 

  The implementation of knowledge and advisory services is beneficial for a better 
follow-up, 

understanding  of  environmental  perspectives  and  appropriate 
including implementation choices at farm level. 

At the level of the CAP,  

  potential  inconsistencies/overlaps  in  the  design  of  the  policy  can  hinder  the 

overall outcomes of sustainable management of natural resources; 

 

 

including ANC payments in the 30% earmarking of EAFRD could result in a less 
efficient  use  of  the  funds  targeting  measures  with  direct  environmental  benefits 
beyond conditionality; 

the policy design does not address certain pressures and needs (see relevance) in a 
sufficient manner, or at all, leaving room for improving the relevance of the CAP 
in addressing the sustainable management of natural resources; 

  an  overall  assessment  of  the  CAP’s  impact  on  the  sustainable  management  of 
natural resources has not been possible due to the absence of suitable monitoring 
data,  common  definitions  (of  soil,  sustainable  soil  management,  conservation 
agriculture and soil threats), and/or quantified targets in EU legislation (for soil).  

Although the evaluation comes late in the policy discussions on the post-2020 CAP, its 
conclusions validate relevant policy elements proposed for the post-2020 CAP, including 
the need for a more strategic approach to improve targeting, consistency of approach and 
overall  performance  (with  this  in  mind,  greater  flexibility  for  Member  States  but  with 
safeguards),  and  improved  funding  and  incentives.  Key  aspects  of  the  Commission’s 
proposal for a post-2020 CAP included the following:  

  a strategic planning approach encompassing most elements in both pillars of the 

CAP together;  

  greater  conditionality  to  replace  the  current  cross-compliance  and  ‘greening’  – 
improving  existing  standards  and  introducing  new  standards  for  water,  soil, 
biodiversity,  landscapes  and  the  climate,  while  also  introducing  the  Water 
Framework Directive  and the Directive on sustainable use of pesticides into  the 
system of conditionality;  

  eco-schemes in pillar I - supporting voluntary action going beyond conditionality 

and other obligations (e.g. agro-ecology and precision farming); 

  ongoing  possibilities  of  support  through  CAP  pillar  II  for  environment-  and 
climate-related  farming  and  forestry  practices,  investments,  knowledge-building 

89 

 
 
and  innovation  –  with  ANC  payments  no  longer  taken  into  account  for  the 
mandatory  minimum  spending  level  on  the  environment  and  climate  of  30%  of 
the EAFRD150; 

  stronger  links  with  EU  legislation  on  climate  change,  energy,  water,  air  and 

pesticides;  

  an explicit obligation for Member States to show greater ambition to address the 
environment and climate through the CAP than in the 2014-2020 policy period.  

Most  of  these  elements  survived  in  essence  in  the  political  agreement  reached  by  the 
Council and the European Parliament. 

The  Commission  proposal  also  introduced  a  performance  monitoring  and  evaluation 
framework including a set of common indicators, data collection and regular reporting on 
performance,  monitoring  and  evaluation  activities  to  help  the  CAP  move  from 
compliance  to  results  and  to  better  explain  the  CAP’s  achievements  and  simplify  the 
administrative burden linked to monitoring (by using satellite imagery and other modern 
technological solutions). 

To better assess the CAP’s impact on biodiversity, two impact indicators were added to 
the  new  performance  monitoring  and  evaluation  framework  (PMEF).  These  are 
indicators  on  habitats  and  species  (relying  on  Member  States’  notifications  to  the 
Directorate-General for Environment) and landscape elements (under development by the 
Joint Research Centre and the European Environmental Agency). In addition, to improve 
data completeness, the use of notifications to other Directorates-General were enhanced 
and legal  bases  were introduced  where needed,  notably to  replace  data  provision  based 
on ‘gentlemen agreements’ (e.g. for gross nutrient balances).  

In  addition,  the lack of information  on farming practices  will be solved by  the detailed 
explanations on interventions implemented by Member States in the CAP plans and the 
detailed reporting by interventions in the annual performance reports. 

Whatever  the  case,  the  difficulty  of  quantifying  the  net  impact  of  the  CAP  on  natural 
resources will remain,  given the effects of the other factors playing a role and the time 
needed for outcomes to materialise. 

The findings of the evaluation will inform the Commission’s involvement and support to 
the Member States as they develop their strategic plans for the next CAP period.  

150  As  outcomes  of  negotiations  with  the  European  Council  and  Parliament:  a  mandatory  minimum 
spending  level  of  25%  of  the  direct  payment  budget  was  introduced  for  eco-schemes;  the  minimum 
expenditure on the environment and climate from the EAFRD was increased to 35%; the 35% will also 
include spending on animal welfare, as well as 50% of spending on ANC payments. 

90 

 
 
                                                      
ANNEX 1: PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/CWP references 

The evaluation was approved in the European Commission planning of legal initiatives, 
under  PLAN/2020/6815151.  The  evaluation  was  organised  and  conducted  by  the 
Directorate-General for Agriculture and Rural Development (DG AGRI), according to its 
evaluation and studies plan. 

2.  Organisation and timing 

This  evaluation  was  included  in  the  DG  AGRI  evaluation  plan.  It  followed  the  ‘better 
regulation’ guidelines for evaluations. The evaluation incorporated the work  carried out 
through  three  individual  external  studies  (on  biodiversity,  soil  and  water)  that  were 
contracted  through  a  service  request  under  a  framework  contract.  The  work  was 
supervised under the technical and contractual management of AGRI unit C.4 in charge 
of monitoring and evaluation. 

An  interservice  steering  group  was  set  up  by  the  Commission  on  7  April  2020,  to:  (i) 
ensure  that  all  relevant  policy  areas  are  considered  through  the  participation  and 
contribution of experts to the draft evaluation staff working document; and (ii) comment 
on the draft open public consultation that will contribute to the staff working document. 

The  interservice  steering  group  was  composed  of  the  Secretariat-General  of  the 
Commission and DGs AGRI, BUDG, CLIMA, COMP, ENER, ENV, ESTAT, GROW, 
JRC,  REGIO  and  SANTE,  and  involved  the  European  Environment  Agency.  The 
interservice  steering  group  held  its  first  meeting  on  8  May  2020  to  discuss  the  context 
and  envisaged  process  and  exchange  on  the  draft  public  consultation.  The  second 
meeting was held on 28 April 2021 to discuss the draft staff working document before its 
submission to the Regulatory Scrutiny Board.  

The evaluation had no individual roadmap. The roadmap consultations on the underlying 
evaluations  ran  between  29 October – 26 November 2018  on  water  (12  replies), 
8   November   –   6 December 2018  on  biodiversity  (36  replies)  and  30 July – 27 August 
2019 on soil (18 replies). An online public consultation was carried out between 9 July -
22 October 2020 (see Annex 2). 

3.  Exceptions to the ‘better regulation’ guidelines 

No  exceptions  were  requested  for  the  evaluation,  apart  from  the  merger  of  the  three 
underlying evaluations on biodiversity, soil and water. 

4.  Consultation of the Regulatory Scrutiny Board 

The  Regulatory  Scrutiny  Board  scrutinised  the  evaluation  report  at  a  meeting  on 
2 June 2021, and provided a positive opinion. However, the  Board also  considered that 
the report should be improved regarding the following aspects. 

151  Replacing PLAN/2018/4284 (biodiversity), PLAN/2018/4340 (water) and PLAN/2019/5582 (soil). 

91 

 
 
 
                                                      
Regulatory Scrutiny Board remark 

Considerations for the report 

1)  The  report  is  not  sufficiently  clear  on 
why  conclusions  cannot  be  drawn  on  the 
effectiveness  of 
assessed  CAP 
the 
measures  for  the  sustainable  management 
of resources. 

The  report  makes  it  clear  that  the  short 
observation period limits the potential of a 
robust  analysis  of  the  impact  of  the  CAP 
on  the  sustainable  management  of  natural 
resources,  in  particular  considering  that 
natural  processes  are  lengthy  and  impacts 
materialise over longer periods. The report 
highlights  that  the  performance  of  the 
CAP 
is  affected  by  various  external 
factors. As such, it is  virtually impossible 
to  estimate  the  net  impact  of  the  CAP  on 
the  sustainable  management  of  natural 
resources. 

conclusions. 

that  only 
The  report  also  highlights 
looking  at  the  available  indicators  during 
the  observation  period  is  insufficient  to 
a  more 
draw 
comprehensive assessment, there would be 
need  for  a  broader  set  of  indicators  on 
specific issues and a sufficient observation 
period  that  provides  representative  and 
robust data. 

For 

2)  The  report  is  not  sufficiently  clear  on 
how its findings can be used in the policy 
process. 

in 

late 

The report acknowledges that although the 
evaluation  comes 
the  policy 
discussions  on  the  post-2020  CAP,  its 
conclusions  validate 
relevant  policy 
options  proposed  for  the  post-2020  CAP, 
including  the  need  for  a  more  strategic 
approach  to  improve  the  targeting  of 
funding  and 
improved 
interventions, 
incentives,  while  putting  safeguards  in 
view  of  the  flexibility  left  to  Member 
States. 

The findings of the evaluation should also 
inform  Member  States  in  the  context  of 
developing  their  national  CAP  Strategic 
Plans  for  the  next  CAP  period,  and  guide 
the  Commission  when  approving 
the 
strategic plans. 

5.  Evidence, sources and quality  

Relevant data and information were gathered in the evaluation support studies, the public 
consultation  and  from  a  broad  range  of  sources,  to  build  an  evidence  basis  for  the 
evaluation (see Annex 3). 

92 

 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

A  number  of  consultation  activities  were  carried  out  at  different  points  in  time  for  the 
elaboration  of  the  evaluation,  including  consultations  by  the  Commission  and  surveys 
and interview in the context of the studies on biodiversity, soil and water.  

Regarding the consultations carried by the contractors for, and during, the elaboration 
of the evaluation support studies on biodiversity, soil and water, these took the form of 
interviews  with  key  stakeholders.  They  were  used  to  gather  in-depth  qualitative 
information and the opinions of key stakeholders (managing authorities, researchers and 
other  local  experts  working  on  agricultural  soils,  farmer  representatives  and  advisors, 
NGOs) relative to context, implementation and results in the case study countries. Some 
additional  interviews  were  conducted  with  specific  project  managers  and  researchers. 
Each of the evaluation support studies also carried out a survey with farm advisors in the 
case-study Member States. It collected qualitative information on the drivers and choices 
made by the farmers regarding their practices and their uptake of innovations. Interviews 
and surveys were then used in all of the replies to the evaluation study questions by the 
contractors (except on soil where survey was only used for answering to the question 9). 

The Commission has also carried a number of consultations, starting with the individual 
roadmaps for the evaluations of the impact of the CAP on the sustainable management 
of biodiversity, soil and water. The feedback of the roadmaps took place from 29 October 
2018  to  26  November  2018  for  water,  8  November  2018  to  6  December  2018  for 
biodiversity and 30 July 2019 to 27 August 2019 for soil. These roadmaps included key 
aspects to be covered by the evaluation, such as purpose and scope, data collection and 
methodology, consultation of citizens and stakeholders. The total  feedback received for 
the three roadmaps were 66 responses from citizens, sectorial and industry associations, 
business organisations, environmental NGOs, confederation of service providers, public 
administrations, among others.  

The  overall  position  of  respondents  about  the  roadmaps  was  neutral,  deeming  the 
evaluations  necessary  and  raising  points  for  the  analysis  of  the  impact  of  the  CAP  on 
biodiversity,  soil  and  water.  The  difference  between  user  types  did  not  yield  major 
differences in the kind of answers provided. A large number of respondents (notably to 
the  roadmap  consultation  on  biodiversity)  pointed  to  the  importance  of  agricultural 
emissions,  even  if  the  subject  was  not  in  the  scope  of  the  evaluation,  but  covered  by  a 
specific  evaluation.  Overall, the feedback to  the roadmap consultations provided useful 
input  to  the  drafting  of  the  relevant  technical  specifications  on  the  evaluation  support 
studies when not covered already in the relevant evaluation approaches.  

The  public  consultation  on  the  evaluation  of  the  EU  common  agricultural  policy’s 
impact  on  biodiversity,  soil  and  water  (natural  resources)  was  conducted  from  9  July 
2020  to  22  October  2020  via  EU  Survey.  It  was  a  comprehensive  consultation  with 
specific  questions  covering  biodiversity,  soil  and  water  and  the  individual  evaluation 
criteria of effectiveness, efficiency, relevance, coherence and EU added value. 

A total of 183 contributions were received from 25 EU Member States152 and Israel with 
different levels of replies. 

152  Including the UK, which was considered as a Member State for the purpose of the consultation (and in 

line with the observation period). There were no contributions from Croatia, Malta and Lithuania. 

93 

 
 
                                                      
Figure 25 Number of respondents to the public consultation by country of origin 

58

18

9

6

13

14

21

10

Belgium
Bulgaria
Czechia
Denmark
Germany
Estonia
Ireland
Greece
Spain
France
Italy
Cyprus
Latvia
Luxembourg
Hungary
Netherlands
Austria
Poland
Portugal
Romania
Slovenia
Finland
Slovakia
Sweden
United Kingdom
Israel

1

3

2

2

2

1
1

3

2

4
4

2

2

1

1
1
1
1

0

10

20

30

40

50

60

70

Source: public consultation 

Figure 26 Number of respondents to the public consultation by affiliation 

Consumer 
Organisation; 1

Academic/Researc
h Institution; 8

Business 

Association; 18 Environmental 
Organisation; 4

Othe
r; 15

Public 
authority; 
20

EU Citizen; 86

NGO (Non-
governmental 
organisation); 21

Company/Business 
organisation; 10

Source: public consultation 

EU Citizens provided the most contributions to this consultation accounting for 47% of 
all  respondents  (number  of  responses  ‘N’=86),  followed  by  NGOs  for  11%  of  all 
respondents  (N=21), public authorities for 11% of all respondents  (N=20) and business 
associations 
respondents, 
company/business  organisation  accounted  for  5%  of  the  total  responses  (N=10), 
academic/research  institutions  4%  (N=8),  environmental  organisations  2%  (N=4)  and 
consumer  organisations  less  than  1%  (N=1).  The  remaining  9%  (N=15)  of  respondents 
identified themselves as ’others’.  

for  11%  of  all 

(N=18).  Of  all 

respondents 

the 

On  the  sectors  represented  by  the  respondents,  ‘agriculture  (farming)’  is  the  most 
common, with 65 respondents (36%), followed by ‘environmental protection sector’, 32 

94 

 
 
 
 
(18%), ‘civil society’, 19 (10%), ‘farm advisory services’, 12 (7%), ‘forestry, including 
agri-forestry’,  with  8  responses  (4%),  ‘development  of  rural  areas’,  7  (4%)  and  lastly, 
‘input  producers  (i.e.  fertilisers,  pesticides,  seed,  machinery)’  and  ‘other  service 
providers and agricultural contractors’, both with 2 answers. The rest (35%) corresponds 
to ‘other’ sectors. 

Analysis of results 

A majority of respondents consider that the CAP contributed to the achievement of the 
environmental objectives of the EU to  a very large  extent, to  a large  extent  or to  some 
extent. However, the perception varies across the different objectives, with biodiversity 
and  soil  receiving  the  highest  rate  of  positive  (very  large  or  large  extent)  replies  and 
climate and GHG the highest rate of negative (not at all) replies. 

Figure 27 CAP contribution to environmental objectives of the EU 

5%

9%

35%

22%

23%

5%

Adapting to climate change (N=171)

8%

18%

27%

29%

12%

6%

Fostering carbon conservation and sequestration in
agriculture and forestry (N=164)

8%

13%

34%

20%

17%

8%

Reducing ammonia emissions from agriculture (N=164)

6%

16%

31%

21%

20%

6%

Reducing greenhouse gas emissions from agriculture
(N=166)

6%

26%

28%

27%

11%

1%

Restoring, preserving and enhancing biodiversity, habitats
and landscapes (N=168)

8%

23%

32%

22%

15%

1%

Preventing soil erosion and improving soil management
(N=166)

7%

19%

33%

29%

7%

5%

Improving water quality (N=177)

2%

14%

36%

31%

9%

8%

Increasing efficiency in water use by agriculture (N=177)

To a very large extent

To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation 

Responses on the main drivers of success in the implementation of CAP instruments and 
measures  to  contribute  to  sustainable  management  of  natural  resources  confirm  the 
prominent role of ‘voluntary commitments (e.g. AECM, organic farming)’. 

95 

 
 
 
Figure 28 Drivers of success in CAP implementation contributing to sustainable management 
of natural resources 

Source: public consultation 

Figure 29 Main factors limiting CAP implementation contributing to sustainable management 
of natural resources 

Source: public consultation 

96 

 
 
 
 
Answers  to  the  question  on  the  main  factors  that  limit  the  contribution  to  sustainable 
management  of  natural  resources  through  the  implementation  of  the  current  CAP 
instruments and measures pointed to the ‘insufficient level of financial incentives’, ‘low 
ambition  of  the  measures’,  ‘an  insufficient  budget  allocation’,  ‘the  lack  /quality 
/independency  of  farm  advice’  and  ‘disproportionate  administrative  burden  for 
beneficiaries (fear of excessive controls)’ as the most important elements. 

Regarding  the  question  on  the  effectiveness  of  the  CAP  instruments  that  contribute  to 
sustainable  management  of  biodiversity,  habitats  and  landscapes,  the  instruments  that 
were perceived the most effective were the support to organic farming (47%), investment 
support  for  forestry  (afforestation,  agroforestry)  (45%),  Natura  2000  and  Water 
Framework  Directive  payment  (43%).  On  the  other  hand,  the  instruments  that  were 
perceived  the  least  effective  were  the  mandatory  practices  (GAEC)  without  financial 
support (46%), and investment sup-port on farms (45%). 

Concerning the question on the effectiveness  of  the CAP  instruments  that  contribute to 
sustainable  management  of  soil  resources,  the  instruments  that  were  perceived  as  most 
effective (sum of ‘very large’ and ‘large’ extent) by the respondents, were the support to 
organic  farming  (47%)  agri-environment-climate  voluntary  commitments  (39%)  and 
mandatory practices with financial support (Greening) (39%). The instruments that were 
perceived  least  effective  by  respondents  (sum  of  ‘very  small  extent’  and  ‘not  at  all’), 
were the investment support on farms (35%), cooperation (33%) and mandatory practices 
(GAEC) without financial support (33%). 

Regarding  the  question  on  the  effectiveness  of  the  CAP  instruments  that  contribute  to 
sustainable management of water in terms of water quantity (in %), the instruments that 
were perceived the most effective were investment support on farms (33%), Natura 2000 
and Water Framework Directive payments (33%), knowledge transfer and advice (32%) 
and  innovation  (40%).  The  CAP  measures  and  instruments  that  were  perceived  as  the 
least  efficient  were  mandatory  practices  (GAEC)  without  financial  support  (35%)  and 
linking CAP support to compliance with specific non-CAP regulatory provisions (SMR) 
(35%). 

Concerning the question on the effectiveness  of  the CAP  instruments  that  contribute to 
sustainable  management  of  water  in  terms  of  water  quality,  the  instruments  that  were 
perceived  the  most  effective  were  support  to  organic  farming  (41%),  Natura  2000  and 
Water  Framework  Directive  payments  (39%)  and  agri-environment-climate-voluntary 
commitments  (AECM) (37%). The CAP  measures and instruments  that were perceived 
the  least  efficient  were  mandatory  practices  (GAEC)  without  financial  support  (38%), 
support to areas with natural constraints (35%) and cooperation (33%). 

A large share of respondents could not determine the effect of the implementation of the 
de-coupled income support and the voluntary coupled support on natural resources (40% 
and  43%  respectively).  For  sectoral  programmes  and  other  CAP  instruments,  the 
responses were mixed, but in both cases the highest shares were given to ‘negative effect’ 
(30% and 32% respectively). 

Respondents  have  a  generally  positive  perception  about  the  extent  to  which  the  CAP 
instruments  and  measures  implemented  by  the  Member  States  for  the  sustainable 
management of natural resources with its available budget is relevant (or not). Exceptions 
to  this  are  the  mandatory  practices  (GAEC)  without  financial  support,  mandatory 
practices with  financial  support (greening),  and linking CAP  support to  the compliance 
with specific non-CAP regulatory provisions (SMR). 

97 

 
 
According  to  the  replies,  the  main  aspects  of  administrative  cost/burden  in  the 
implementation of the current  CAP  instruments  and measures to  achieve the objectives 
relevant  to  sustainable  management  of  natural  resources  fall  on  beneficiaries  (61%), 
followed  by  ad-ministrations  (33%)  and  other  (6%).  For  beneficiaries  the  major 
cost/burden  is  the  ‘complexity  to  submit  an  aid  application’  (36%),  followed  by  ‘too 
much  time  and  effort  required  for  administrative  controls’  (23%),  ‘too  much  time 
required  to  receive  the  payment  after  sub-mitting  the  aid  application’  (21%)  and  ‘too 
frequent  changes  in  the  policy’  (20%).  For  administrations  the  clear  source  of 
cost/burden are ‘too frequent changes in the policy’ (51%), followed by ‘complexity of 
management  in  the  administrative  system’  (35%)  and  the  ‘complexity  due  to  a 
decentralized administrative system’ (14%). 

Figure  30  Extent  to  which  the  relevant  applicable  CAP  instruments  and  measures  as 
implemented  by  the  Member  States  for  the  sustainable  management  of  natural  resources 
generate the best possible results on management of natural resources with its available budget 

13%

16%

34%

15%

3%

19%

Sectoral Programmes for fruit and vegetables (N=172)

13%

22%

25%

15%

5%

20%

Innovation (N=174)

18%

17%

33%

15%

4%

13%

Cooperation (N=172)

12%

18%

32%

11%

6%

22%

Knowledge transfer and advice (N=171)

14%

32%

21%

15%

6%

12%

Investment Support for forestry (N=171)

17%

18%

19%

28%

6%

12%

Investment Support on farms (N=172)

14%

30%

26%

15%

3%

12%

Natura 2000 and Water Framework Directive payments
(N=169)

10%

12%

30%

21%

15%

13%

11%

Support to areas with natural constraints (N=172)

40%

21%

13%

5%

9%

Support to Organic farming (N=170)

7%

19%

29%

13%

7%

25%

Voluntary commitments for forestry  (N=172)

10%

36%

24%

16%

6%

8%

8%

25%

24%

20%

14%

9%

7%

9%

27%

34%

11%

11%

Agri-environment-climate voluntary commitments (AECM)
(N=173)

Mandatory practices with financial support (greening)
(N=171)
Mandatory practices (GAEC) without financial support
(N=169)

8%

16%

31%

26%

6%

13%

Compliance with non-CAP provisions (SMR) (N=173)

To a very large extent To a large extent

To some extent

To a very small extent Not at all

No opinion

Source: public consultation 

A significant share of the respondents considers that the CAP instruments and measures 
which  contribute  to  sustainable  management  are  coherent,  ‘to  some  extent’  (with  70 
responses out of 170, i.e. 40%). 38 (21%) replied ‘coherent to a very small extent’, ‘not 
at all coherent’ was chosen by 29 (16%), ‘to a large extent’ by 30 (17%) and ‘to a very 
large extent’ by 4 (2%) of the respondents. 

Regarding the coherence of the applicable CAP instruments and measures regarding the 
sustainable  management  of  natural  resources,  the  instruments  that  were  perceived  the 
most positively (sum of ‘fully coherent’ and ‘mostly coherent’) were: Water Framework 
Directive (37%) Nitrates Directive (36%) Habitats  Directive (33%). On the other hand, 
the  instruments  and  measures  perceived  the  least  coherent  were:  Sustainable  Use  of 

98 

 
 
 
Pesticides  Directive  (32%)  EU  Biodiversity  Strategy  to  2020  (29%)  EU  strategy  on 
adaptation to climate change (29%). 

The overwhelming majority of the respondents  found either very relevant  or somewhat 
relevant  the  available  CAP  instruments  and  measures  to  respond  to  the  actual  needs  in 
terms  of sustainable management of soil within the EU. This  perception is  kept  for the 
relevance  of  the  instruments  and  measures  to  the  needs  of  sustainable  management  of 
water use, along with that of water quality. 

A significant share of respondents (46% of 183 replies, sum of ‘to a large extent’ and ‘to 
a  very  large  extent’)  found  that  the  relevant  applicable  CAP  instruments  and  measures 
create EU  added value  with  respect  to  sustainable management  of natural  resources, of 
which  16  (9%)  ‘to  a  very  large  extent’  and  65  (37%)  ‘to  a  large  extent’.  On  the  other 
hand,  54  of  the  respondents  (31%)  answered  that  there  is  EU  added  value  ‘to  some 
extent’, 23 (13%) ‘to a  very small  extent’ and 11 (6%) responded that ‘not  at  all’. The 
remaining 7 (4%) did not have an opinion. 

Analysis of the position papers 

24  position  papers  were  submitted  as  attachments  with  the  replies  to  the  public 
consultation.  Most  of  the  respondents  submitting  a  position  paper  welcomed  the 
opportunity  to  present  their  views  on  the  sustainable  management  of  the  EU  CAP 
instruments  and  measures,  especially  in  the  context  of  the  Farm  to  Fork  Policy,  the 
European Green Deal and the new CAP for the 2021-2027 period, even if the content of 
the consultation concerned the past performance of the CAP.  

Food  production  was  a  major  topic  for  respondents,  along  with  agricultural  production 
(highlighting sustainable and organic production) and contributions were provided on the 
new CAP  plan.  In accordance, respondents  also  supported the use of this questionnaire 
for the elaboration of the new CAP, but lamented that the questionnaire came late for it.  

Some of the respondents also, similarly to the roadmap analysis, provided new evaluation 
criteria and sources, but there was no clear-common view on this between respondents. 
Funding allocation was also suggested as a potential change, but there was not common 
point  among  respondents.  There  was  a  common  ground  on  maintaining  the  level  of 
funding  to  the  CAP,  especially  among  farmers,  as  it  is  found  as  a  requirement  for 
achieving  the  sustainability  and  greening  objectives  of  the  future  CAP.  Some  other 
respondents  emphasised  that  more  resources  (from  the  overall  CAP  share)  should  be 
allocated  to  the  greening  measures  to  increase  the  sustainable  management  of  natural 
resources,  with  mentions  to  all  three  natural  recourses  from  different  respondents. 
Another source of common point is the administrative burden the CAP can represent for 
farmers, and thus it is asked for the new CAP to be kept simpler. 

99 

 
 
 
 
ANNEX 3: METHODS AND ANALYTICAL MODELS 

The  methodological  approach  to  the  evaluation  combined  quantitative  and  qualitative 
analysis,  including  a  literature  review,  desk  research,  econometric  analysis,  surveys, 
interviews and case studies, primarily as part of the external and independent evaluation 
support studies carried out by Alliance Environnement. DG AGRI further complemented 
the  studies  with  additional  analysis  (using  up-to-date  statistics)  and  synthesis  of  newly 
available literature. 

Table 9 Description of the data collection and analytical tools 

Method/Tool 

Brief description of tool 

Data collection tools 

/ 

Documentary 
research 
Literature 
reviews 
/ 
statistical  data 
analysis 

Surveys 

Case studies 

Analytical tools 

Stakeholder 
analysis 

The  study  encompassed  a  review  of 
the  available 
bibliography  with  regards  to  the  implementation  and 
impacts  of  the  CAP.  That  included  in  particular  previous 
studies  of  the  CAP  at  the  EU  level,  as  well  as  previous 
evaluation studies, rural development programmes (RDPs) 
and  their  annual  implementation  reports  (AIRs)  in  the 
case-studies areas. 
Specific  literature  reviews  have  been  performed  on  key 
subjects: 
-  The  theoretical  effects  of  changes  in  pressures  of 

water quality, quantity, soil and biodiversity  

-  The  role  played  by  agricultural  practices  on  water 

related pressures, soil and biodiversity 

-  Effects of agricultural and  forest activities on  water, 

soil and biodiversity; 

-  Effects  of  key  soil-relevant  practices  on  soil 

productivity;  

-  Technological  and  social  innovations  expected  or 
proven  to  have  a  significant  impact  on  natural 
resources;  

-  Effects  of  operations  similar  to  those  supported  by 

the CAP, in the EU member states and abroad. 
Used  to  gather  data  from  a  small,  non-representative 
sample of farmers in each of 10 case study countries (from 
each of the evaluation support studies) on their experience 
of  sustainable  management  of  natural  resources,  its 
pressures  and  relevant  CAP  instruments.  Also  used  with 
farm advisers to gain information on the extent of uptake 
of different types of innovation and cooperation.   

Case  studies  are  used  as  an  evaluation  tool  when  ‘how’ 
and  ‘why’  questions  are  being  posed.  They  allow  a 
detailed examination of specific issues to be carried out in 
line with the evaluation goals. 

Stakeholder  analysis  was  carried  out  at  each  step  of  the 
evaluation  study,  in  order  to  prepare  interviews  with  the 
relevant stakeholders and to  analyse the information they 
provided  in  the  light  of  their  levels  of  participation, 
interests and influence on the CAP implementation on the 
sustainable management of natural resources 

Matrix scoring  The  scoring 

involves  qualitative 

judgements  of  the 
interactions  to  be  carried  out  and  requires  triangulation 
with other data sources to ensure the analysis is robust 

Type of tool 

Relevant  evaluation 
questions’ chapter 

All  

Qualitative 
& 
quantitative 

Quantitative 
and 
qualitative 

Causal analysis 
Effectiveness  

All 

Qualitative 
& 
quantitative 

Qualitative   All 

All 

Qualitative 
and 
quantitative  

100 

 
 
 
Method/Tool 

Brief description of tool 

Counterfactual  Used  to  analyse  the  effects  of  measures  by  comparing 
situations  between  beneficiaries  and  non-beneficiaries  of 
measures.  

Type of tool 

Relevant  evaluation 
questions’ chapter 

Qualitative 

EU Added-value 

The  case  studies  provide  detailed  and  context-specific  qualitative  and  quantitative 
information to complement the EU-wide information collected to inform the analysis and 
answers  to  the  evaluation  questions.    The  information  was  gathered  through  interviews 
with key stakeholders, including advisers and representatives of the farming, forestry and 
wider 
representatives  and 
regional  and  national  government 
environmentalist researchers and NGOs, and by sourcing and analysing national/regional 
literature, statistics and other data sources. All information from the case studies has been 
carefully interpreted to determine what generic conclusions can be drawn from them for 
the analysis and answers to the evaluation questions. 

sectors, 

rural 

Table 10 Case studies selection criteria, by natural resources 

Biodiversity 

Soil 

Water 

Biogeographical  characteristics 
and main land use types 

Biogeographical zones 

Farm  sector  structure  and  land 
management 

National policy framework 

Habitats  and  biodiversity  trends 
in the agricultural sector 

Intensity 
production 

and  methods 

of 

instrument  and  measure 

CAP 
implementation choices 

Implementation choices of soil-
related  CAP  instruments  and 
measures 

Intensity of soil threats 

criteria 

for 
Selection 
water  is  made  according 
the  River  Basin 
to 
District 
(RBDs) 
geographical  features,  as 
it  is  the  implementation 
level  of  the  River  Basin 
Management 
Plants 
(RBMPs) 

Table 11 Case Studies at EU level on water, biodiversity and soil, by countries 

Biodiversity 

Soil 

Water 

Germany  (Land  of  Baden-
Württemberg) 
France (department of Val de 
Loire) 

Croatia 
Hungary 
Ireland 
Latvia 

Netherlands 

Portugal 

Romania 

Slovakia 

Belgium (Wallonia) 

Austria  

Bulgaria  

Czechia  
Germany (Bavaria) 
Denmark  
Greece  

Spain (Aragon) 

Ireland 

Italy (Toscana) 

Sweden 

101 

Germany 
Rhine Westphalia) 

(North-

Spain (Aragon) 
Finland 
France (Alsace)  
Croatia 

Italy (Apulia) 

Netherlands  

Poland 

Romania  

 
 
 
 
 
 
Limitations and robustness of findings 

There  were  methodological  challenges  in  establishing  the  results  that  have  occurred 
related to  natural  resources. These implicate limitations of the analysis and weaken the 
robustness of the findings. The main challenges are listed below: 

  Complex  cause-effect  relationships  associated  with  specific  farm  and  forest 
practices  and  their  different  environmental  impacts  in  different  locations  and  at 
different  scales,  which  make  it  difficult  to  measure  the  net  impact  of  a  given 
measure. 

  Despite the extensive monitoring of the CAP and data collection from EU farms, 
the available databases do not make it possible to assess the effects of the CAP on 
natural resources  at farm nor at local level,  especially on soil and water quality. 
Its  impacts  could  be  approached  only  through  expected  effects  and  changes  in 
general impact metrics. 

  A specific effect of a measure of the CAP on one of natural resources cannot be 
isolated from the effects from another one of the measures targeting the same or 
other  resource.  For  example,  a  natural  resource  sub-measures  may  have  been 
programmed  under  other  focus  areas  or  priorities  when  the  actions  also  benefit 
other objectives (e.g. farm competitiveness affecting water.) 

  Difficulties  in  accessing  data.  Issues  regarding  FADN  were  already  assessed  in 
chapter  4.  For  other  cases,  like  water,  Water  Information  System  for  Europe 
(WISE) data are available for the two periods of time covered by the River Basin 
Management  Plants,  but  the  specific  year  when  the  data  were  collected  is  not 
mentioned. The use of surveys to farmers and stakeholder interviews allowed to 
circumvent some of these issues. 

 

Issues  of  scaling  up  results  from  case  studies  to  form  generalised  judgments  at 
EU  level.  The  case  studies  are  chosen  to  represent  the  variety  of  environments 
present  in  the EU, but  does not  make the choices representative at  EU level  for 
extrapolation purposes. 

All these limitations inevitably have an impact on the robustness of the conclusions that 
can be drawn.   

102 

 
 
 
 
ANNEX 4: TABLES AND FIGURES COMPLEMENTING CHAPTER 2 

Table 12 Rules on cross-compliance 

Area 

Main Issue 

Requirements and standards 

Water 

Environment, 
climate 
change, good 
agricultural 
condition of 
land 

SMR 1  Council Directive 91/676/EEC of 12 December 
1991 concerning the protection of waters against 
pollution caused by nitrates from agricultural 
sources (OJ L 375, 31.12.1991, p. 1) 

Articles 4 
and 5 

GAEC 1  Establishment of buffer strips along water courses 

GAEC 2  Where use of water for irrigation is subject to 
authorisation, compliance with authorisation 
procedures 

GAEC 3  Protection of ground water against pollution: 

prohibition of direct discharge into groundwater and 
measures to prevent indirect pollution of 
groundwater through discharge on the ground and 
percolation through the soil of dangerous 
substances, as listed in the Annex to Directive 
80/68/EEC in its version in force on the last day of 
its validity, as far as it relates to agricultural activity 

Soil and 
carbon stock 

GAEC 4  Minimum soil cover 

GAEC 5  Minimum land management reflecting site specific 

conditions to limit erosion 

GAEC 6  Maintenance of soil organic matter level through 

appropriate practices including ban on burning 
arable stubble, except for plant health reasons 

Biodiversity  SMR 2  Directive 2009/147/EC of the European Parliament 

and of the Council of 30 November 2009 on the 
conservation of wild birds (OJ L 20, 26.1.2010, p. 7) 

Article 3(1), 
Article 
3(2)(b), 
Article 4(1), 
(2) and (4) 

Public health, 
animal health 
and plant 
health 

SMR 3  Council Directive 92/43/EEC of 21 May 1992 on 

the conservation of natural habitats and of wild flora 
and fauna (OJ L 206, 22.7.1992, p. 7) 

Article 6(1) 
and (2) 

Landscape, 
minimum 
level of 
maintenance 

GAEC 7  Retention of landscape features, including where 

appropriate, hedges, ponds, ditches, trees in line, in 
group or isolated, field margins and terraces, and 
including a ban on cutting hedges and trees during 
the bird breeding and rearing season and, as an 
option, measures for avoiding invasive plant species 

Food safety  SMR 4  Regulation (EC) No 178/2002 of the European 

Parliament and of the Council of 28 January 2002 
laying down the general principles and requirements 
of food law, establishing the European Food Safety 
Authority and laying down procedures in matters of 
food safety (OJ L 31, 1.2.2002, p. 1) 

SMR 5  Council Directive 96/22/EC of 29 April 1996 

concerning the prohibition on the use in 
stockfarming of certain substances having a 
hormonal or thyrostatic action and beta-agonists, 
and repealing Directives 81/602/EEC, 88/146/EEC 
and 88/299/EEC (OJ L 125, 23.5.1996, p. 3) 

103 

Articles 14 
and 15, 
Article 17(1) 
and Articles 
18, 19 and 20 

Article 3(a), 
(b), (d) and 
(e) and 
Articles 4, 5 
and 7 

 
 
  
  
  
  
  
  
 
  
Identification 
and 
registration of 
animals 

SMR 6  Council Directive 2008/71/EC of 15 July 2008 on 

identification and registration of pigs (OJ L 213, 
8.8.2005, p. 31) 

SMR 7  Regulation (EC) No 1760/2000 of the European 

Parliament and of the Council of 17 July 2000 
establishing a system for the identification and 
registration of bovine animals and regarding the 
labelling of beef and beef products and repealing 
Council Regulation (EC) No 820/97(OJ L 204, 
11.8.2000, p. 1) 

SMR 8  Council Regulation (EC) No 21/2004 of 17 

December 2003 establishing a system for the 
identification and registration of ovine and caprine 
animals and amending Regulation (EC) 
No 1782/2003 and Directives 92/102/EEC and 
64/432/EEC (OJ L 5, 9.1.2004, p. 8) 

SMR 9  Regulation (EC) No 999/2001 of the European 
Parliament and of the Council of 22 May 2001 
laying down rules for the prevention, control and 
eradication of certain transmissible spongiform 
encephalopathies (OJ L 147, 31.5.2001, p. 1) 

SMR 10  Regulation (EC) No 1107/2009 of the European 

Parliament and of the Council of 21 October 2009 
concerning the placing of plant protection products 
on the market and repealing Council Directives 
79/117/EEC and 91/414/EEC (OJ L 309, 
24.11.2009, p. 1) 

Animal 
diseases 

Plant 
protection 
products 

Animal 
welfare 

Animal 
welfare 

SMR 11  Council Directive 2008/119/EC of 18 December 

2008 laying down minimum standards for the 
protection of calves (OJ L 10, 15.1.2009, p. 7) 

SMR 12  Council Directive 2008/120/EC of 18 December 

2008 laying down minimum standards for the 
protection of pigs (OJ L 47, 18.2.2009, p. 5) 

SMR 13  Council Directive 98/58/EC of 20 July 1998 
concerning the protection of animals kept for 
farming purposes(OJ L 221, 8.8.1998, p. 23) 

Source: Regulation (EU) No 1306/2013, Annex II (see Figure 1) 

Articles 3, 4 
and 5 

Articles 4 
and 7 

Articles 3, 4 
and 5 

Articles 7, 
11, 12, 13 
and 15 

Article 55, 
first and 
second 
sentence 

Articles 3 
and 4 

Article 3 and 
Article 4 

Article 4 

104 

 
 
ANNEX 5: BENCHMARK: THE SITUATION PRIOR TO THE 2014-2020 CAP  

In 2012, EU-28 total utilised agricultural area (UAA) stood at 178.2 million hectares, of 
which  permanent  grassland  and  meadow  accounted  for  33.2%153.  The  share  of  the 
different land cover  categories varies  across  the  EU  and is  correlated  with  the physical 
characteristics of the territory such as mountains and remoteness of the area. Agricultural 
area accounted for 45.5% of total area, natural  grassland  2.4%, total forest area 31.7%, 
transitional woodland shrub 4.8%, and natural area 5.0%154. 
Areas facing natural and other specific constraints (ANCs) accounted for 54.4% of total 
UAA in 2005, with 16.2% mountain areas, 34.4% other areas and 3.8% areas affected by 
specific constraints155. 
In  2013,  UAA  managed  by  farms  with  high  input  intensity  per  hectare  accounted  for 
36.6% of total UAA156. In 2010, 29% of the UAA in the EU-28 was devoted to extensive 
grazing157, with a total amount of 50 million hectares, albeit with significant differences 
among the Member States. 
Natura 2000 areas (including natural grassland) accounted for 10.9% of UAA in 2011158. 
The farmland birds index stood at 81.9% in 2013 (compared to 2000), following a steady 
decline since 2000159. The grassland butterflies population index stood at 66.5% in 2013 
(compared to 1990)160 
The  conservation  status  of  agricultural  habitats  (grassland)  in  2012  was  deemed 
‘favourable’  in  20.9%  of  assessments  of  habitats,  compared  to  38.6%  ‘unfavourable  – 
inadequate’ and 38.2% ‘unfavourable – bad’ (remaining 2% unknown)161. 
High nature value farming accounted for 32.3% of total UAA in 2012162. 
The share of forest  and  other wooded land (FOWL) protected to  conserve biodiversity, 
landscapes  and  specific  natural  elements  stood  at  12.5%  for  biodiversity  conservation 
and 8.6% for protection of landscapes and specific natural elements163. 
The share of irrigated  areas stood at  5.9% of total  UAA in  2013. The volume of water 
applied to soils for irrigation purposes was 39.9 billion m3 in 2010, with a 28.9% share of 
water  abstracted  in  agriculture  for  irrigation  purposes  in  total  gross  abstraction164.  A 

153  CAP context indicator C.18 Agricultural area. 
154  CAP context indicator C.31 Land cover.  
155  CAP context indicator C.32Areas facing natural and other specific constraints (ANCs). 
156  CAP context indicator C.33 Farming intensity. 
157  Extensive  grazing:  livestock  raised  on  food  that  comes  mainly  from  natural  grasslands,  shrublands, 

woodlands, wetlands, and other natural landscapes. 

158  CAP context indicator C.34 Natura 2000 areas.  
159  CAP  context  indicator  C.35  Farmland  birds  index.  The  indicator  is  a  composite  index  measuring  the 
rate  of  change  in  the  occurrence  of  common  bird  species  that  are  dependent  on  farmland  for  feeding 
and nesting and are not able to thrive in other habitats.   

160  Data from European Butterfly Monitoring Scheme. https://butterfly-monitoring.net/.  
161  CAP context indicator C.36 Conservation status of agricultural habitats (grassland). 
162  CAP context indicator C.37 High nature value farming.  
163  CAP context indicator C.38 Protected forest. 
164  CAP context indicator C.39 Water abstraction in agriculture and C.20 Irrigated land.  

Note: the volume of water actually used in agriculture (consumed by animals or evapotranspirated by 
crops) differs from the water abstractions because of the efficiencies in conveyance and application and 
these factors are highly variable across Member States, regions and sub-sectors. 

105 

 
 
 
                                                      
significant  difference  persisted  between  southern  and  northern  Member  States,  with 
Spain, Italy, Greece, Portugal and France accounting for over 96% of the total water used 
for irrigation in the EU. Those countries also showed higher percentages than average of 
irrigated  land  (except  France):  19.8%  for  Greece,  12.8%  Spain,  12.7%  Portugal  and 
5.6%, France165.    
Water  quality  in  terms  of  gross  nutrient  balance  was,  in  2013,  characterised  by 
49 kg Nitrogen/hectare/year for the potential surplus of nitrogen on agricultural land and 
2 kg Phosphorus/hectare/year for the potential surplus of phosphorus on agricultural land. 
The  share  of  monitoring  sites  of  nitrates  in  groundwater  with  a  high  quality  stood  at 
74.1% in 2012, compared to 14.2% with moderate quality and 11.7% with poor quality, 
and  for  surface  water  at  56.9%,  31.7%  and  11.4%  respectively166.  It  was  observed  in 
2013, that the pressure from agriculture was decreasing, although not uniformly, in terms 
of numbers of animals  and consumption of  inorganic fertilisers, continuing a long-term 
trend167.  
Soil organic carbon, the major component of soil organic matter, is extremely important 
in  all  soil  processes,  influencing  its  structure,  aggregate  stability,  nutrient  availability, 
water  retention  and  resilience.  The  total  estimates  of  organic  carbon  content  in  arable 
land  stood  at  14 016.6  mega  tons  in  2012  with  a  mean  organic  carbon  content  of 
43.3 g/kg168.  
An  estimated  32-36%  of  European  subsoils  have  high  or  very  high  susceptibility  to 
compaction169.  About  23%  of  soils  in  the  EU-28  are  estimated  to  have  critically  high 
densities in their subsoils, indicating compaction170.  
Around 45% of the mineral soils in Europe have low or very low organic carbon content 
(0–2 per cent organic carbon)171. 
Most  EU  soils  are  at  risk  for  soil  microorganisms,  fauna  and  biological  functions 
(Orgiazzi et al., 2016).  
In 2013, 24.5% of farms produced at least 3 crops, with 10.9% of farms produced 3 crops 
and 13.6% above 3 crops172. 
The  share  of  estimated  agricultural  area  affected  by  moderate  to  severe  water  erosion 
(>11 t/ha/year) stood at 6.7% of total agricultural area in 2009173. 

165  CAP context indicator C.20 Irrigated land. 
166  CAP context indicator C.40 Water quality, corresponding to CAP impact indicator IMP_11. 
167  Report  on  the  implementation  of  Council  Directive  91/676/EEC  for  the  period  2008–2011. 

(COM(2013) 683 final).   

168  CAP context indicator C.41 Soil organic matter in arable land, corresponding to CAP impact indicator 

IMP_12. 

169  Jones, A., Panagos, P., Barcelo, S., Bouraoui, F., Bosco, C., Dewitte, O., Gardi, C., Erhard, M., Hervás, 
J., Hiederer, R., Jeffery, S., Lükewille,  A., Marno, L., Montanarella, L., Olazábal, C., Petersen, J.-E., 
Penizek,  V.,  Strassburger,  T.,  Tóth,  G.,  Van  Den  Eeckhaut,  M.,  Van  Liedekerke,  M.,  Verheijen,  F., 
Viestova, E. and Yigini, Y. (2012) The State of Soil in Europe , Luxembourg: Publications Office of 
the  European  UnionA  contribution  of  the  JRC  to  the  European  Environment  Agency's  Environment 
State and Outlook Report - SOER 2010). 

170  Schjønning, P., Akker, J., Keller, T., Greve, M., Lamandé, M., Simojoki, A., Stettler, M., Arvidsson, J. 
and Breuning-Madsen, H. (2015) 'Driver-Pressure-State-Impact-Response (DPSIR)  Analysis and Risk 
Assessment for Soil Compaction - A European Perspective', Advances in Agronomy, 133, pp. 183-237. 

171  FAO and ITPS. 2015. Status of the World’s Soil Resources; http://www.fao.org/3/bc590e/bc590e.pdf. 
172  CAP result indicator RPI_11 Crop diversity. 
173  CAP context indicator C.42 Soil erosion by water. 

106 

 
 
 
                                                      
ANNEX 6: INFORMATION COMPLEMENTING CHAPTER 3 

The CAP control and sanction system 

The greening payment is calculated based on the area determined (or the area declared if 
it  is  less  than  the  area  determined).  In  order  to  receive  the  greening  payment  the 
beneficiary has to respect certain requirements related to greening practices referred to in 
Articles 44, 45 and 46 of Regulation (EU) No 1307/2013174. These requirements concern 
crop  diversification,  permanent  grassland  and  ecological  focus  area.  Beneficiaries  that 
comply  with  certain  thresholds  referred  to  in  Article  44  and  46  are  exempt  from  the 
greening requirements. 

Article 31 of Regulation (EU) No 809/2014175 foresees different samples for the purpose 
of the on-the-spot controls (OTSC) with regards to the greening payment. In general, 5% 
of all beneficiaries required to observe greening practices should be checked each year. 
However,  there  are  also  other  cases,  such  as  the  control  sample  of  3%  of  beneficiaries 
who are exempted from the greening requirements. 

In case non-compliances with the greening requirements are detected during a control, a 
reduction  in  the  greening  payment  is  applied.  More  specifically,  Regulation  (EU)  No 
640/2014176 

  Article 24 stipulates that if a non-compliance concerning the crop diversification 
requirement is determined, the area to be used for the calculation of the greening 
payment  shall  be  reduced  by  50%  of  the  total  area  of  arable  land  determined 
multiplied by the ratio of difference. 

  Article 25 stipulates that if a non-compliance concerning the permanent grassland 
requirement is determined, the area to be used for the calculation of the greening 
payment  shall  be  reduced  by  the  area  determined  as  non-compliant  with  the 
requirements. 

  Article 26 stipulates that if EFA required exceeds the EFA determined, the area to 
be used for the calculation of the greening payment shall be reduced by 50% of 
the total arable land determined multiplied by the ratio of difference. 

  Article 27 stipulates that the sum of the reductions expressed in hectares shall not 
exceed the total number of hectares of arable land determined. The total reduction 
shall not exceed the greening payment. 

174  Regulation (EU) No 1307/2013 of the European Parliament and of the Council of 17 December 2013 
establishing  rules  for  direct  payments  to  farmers  under  support  schemes  within  the  framework  of  the 
common  agricultural  policy  and  repealing  Council  Regulation  (EC)  No  637/2008  and  Council 
Regulation (EC) No 73/2009; OJ L 347, 20.12.2013, p. 608–670. 

175  Commission  Implementing  Regulation  (EU)  No  809/2014 of  17  July  2014  laying  down  rules  for  the 
application  of  Regulation  (EU)  No  1306/2013  of  the  European  Parliament  and  of  the  Council  with 
regard  to  the  integrated  administration  and  control  system,  rural  development  measures  and  cross 
compliance; OJ L 227, 31.7.2014, p. 69–124. 

176  Commission  Delegated  Regulation  (EU)  No  640/2014  of  11  March  2014  supplementing  Regulation 
(EU)  No  1306/2013  of  the  European  Parliament  and  of  the  Council  with  regard  to  the  integrated 
administration  and  control  system  and  conditions  for  refusal  or  withdrawal  of  payments  and 
administrative  penalties  applicable  to  direct  payments,  rural  development  support  and  cross 
compliance; OJ L 181, 20.6.2014, p. 48–73. 

107 

 
 
                                                      
In  addition,  administrative  penalties  can  also  apply  as  regards  the  greening  payment 
further to the above-mentioned reductions.  

Article 28 of Regulation (EU) No 640/2014 stipulates that if the area to be used for the 
calculation of the greening payment differs from the area to be used for the calculation of 
the greening payment after application of reduction,  

 

 

 

 

the greening payment shall be calculated on this latter area reduced by twice the 
difference  established  if  that  difference  is  more  than  either  3%  or  two  hectares, 
but no more than 20% of the area to be used for the calculation of the greening 
payment after application of reduction.  

If the difference is more than 20%, no aid shall be granted.  

If  the  difference  is  more  than  50%,  no  aid  shall  be  granted.  Moreover,  the 
beneficiary  shall  be  subject  to  an  additional  penalty  equal  to  the  amount  of  aid 
corresponding to the difference between the area to be used for the calculation of 
the  greening  payment  and  the  area  to  be  used  for  calculation  of  the  greening 
payment after application of reduction. 

If the beneficiary as a result of the on-the-spot-check, contrary to his declaration 
is deemed to be non-exempt from the greening requirements, the area to be used 
for the calculation of the greening payment after application of reduction shall be 
further reduced by10 %. 

108 

 
 
 
ANNEX 7: TABLES AND FIGURES COMPLEMENTING CHAPTER 5 

Table 13 Common agricultural policy budget allocations 2014-2020 (in million EUR) 

Member States 

Direct payments 

Rural development 

Total CAP budget 

Belgium 

Bulgaria 

Czech Republic 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

UK 
Source: European Commission 

3 603 

5 106 

5 985 

6 044 

34 534 

839 

8 507 

14 808 

34 634 

51 354 

1 482 

26 850 

351 

1 452 

3 104 

234 

8 932 

37 

5 223 

4 850 

23 313 

4 105 

11 638 

960 

3 016 

3 662 

4 866 

22 283 

648 

2 367 

2 306 

919 

9 446 

823 

2 191 

4 718 

8 297 

11 385 

2 026 

10 444 

132 

1 076 

1 613 

101 

3 431 

97 

765 

3 938 

8 698 

4 058 

8 128 

838 

1 560 

2 380 

1 764 

5 200 

4 251 

7 472 

8 291 

6 963 

43 980 

1 663 

10 697 

19 526 

42 931 

62 739 

3 508 

37 294 

484 

2 527 

4 717 

335 

12 362 

134 

5 988 

8 787 

32 010 

8 163 

19 766 

1 797 

4 576 

6 042 

6 630 

27 483 

109 

 
 
 
 
 
Table 14. Expenditure on relevant environmental measures 2014-2020 (in million EUR)  

Member State 

2014 

2015 

2016 

2017 

2018 

2019 

Total 

Greening 

European Union 28 

11561.04 

11767.1 

11774.6 

11750.9 

46853.70 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

UK 

151.93 

233.56 

246.99 

256.58 

147.43 

232.15 

249.94 

249.81 

145.80 

233.93 

248.02 

246.10 

141.59 

233.38 

254.41 

244.42 

1437.50 

1431.84 

1422.27 

1414.44 

32.95 

357.15 

510.10 

33.41 

358.76 

518.61 

35.91 

352.64 

525.57 

39.11 

354.72 

521.45 

1355.97 

1389.70 

1404.78 

1394.88 

2061.13 

2147.15 

2096.95 

2015.33 

52.96 

59.56 

71.33 

82.47 

1039.28 

1044.08 

1018.39 

1035.47 

14.94 

52.09 

14.90 

59.55 

14.78 

66.70 

14.44 

73.67 

122.59 

130.32 

137.28 

137.99 

9.76 

9.90 

9.87 

9.77 

380.65 

376.51 

381.81 

379.34 

0.44 

210.82 

198.30 

845.38 

158.79 

397.64 

40.80 

128.02 

151.90 

199.68 

913.14 

0.46 

212.92 

201.22 

859.43 

162.65 

425.36 

40.26 

129.18 

152.19 

202.83 

927.01 

0.50 

208.37 

200.07 

871.38 

165.97 

450.96 

40.33 

130.97 

154.51 

205.51 

933.89 

M4 - Investments 

0.53 

196.25 

200.92 

887.36 

169.21 

474.58 

39.82 

130.96 

154.60 

205.11 

944.71 

586.75 

933.01 

999.36 

996.92 

5706.04 

141.39 

1423.27 

2075.73 

5545.34 

8320.57 

266.32 

4137.22 

59.07 

252.01 

528.17 

39.30 

1518.32 

1.93 

828.36 

800.50 

3463.55 

656.62 

1748.54 

161.20 

519.13 

613.20 

813.13 

3718.76 

European Union 28 

219.67 

981.60 

1635.73 

2364.37 

2813.94 

1554.93 

7795.63 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

29.14 

2.41 

18.89 

4.63 

5.99 

17.86 

8.72 

15.69 

6.42 

19.28 

49.75 

24.22 

9.45 

61.33 

78.41 

74.75 

5.01 

6.04 

55.22 

34.47 

28.82 

24.85 

64.53 

74.71 

26.49 

32.44 

76.79 

80.35 

37.56 

118.75 

132.66 

152.79 

27.78 

14.27 

88.02 

109.29 

108.73 

30.33 

39.25 

31.88 

61.39 

205.81 

248.28 

89.04 

35.84 

40.22 

42.92 

351.96 

275.19 

69.23 

16.43 

35.71 

29.40 

7.87 

97.54 

12.03 

18.34 

40.77 

248.52 

145.81 

46.80 

5.31 

137.80 

131.15 

206.38 

341.04 

222.50 

72.05 

212.22 

195.95 

112.13 

453.95 

127.08 

95.82 

253.67 

745.47 

706.95 

193.60 

816.37 

110 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Member State 

2014 

2015 

2016 

2017 

2018 

2019 

Total 

United Kingdom 

37.26 

European Union 28 

1367.57 

1748.39 

2083.04 

2253.60 

2506.62 

1848.81 

8591.64 

M10 - AECM 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

5.43 

0.16 

1.53 

31.84 

73.01 

27.10 

1.18 

37.01 

1.13 

92.28 

136.61 

0.31 

77.17 

9.64 

14.16 

14.42 

1.76 

64.21 

0.19 

55.28 

120.17 

0.72 

3.47 

11.22 

58.27 

51.02 

161.61 

267.60 

3.45 

39.12 

30.38 

18.25 

62.11 

1.68 

59.73 

77.23 

4.54 

76.00 

6.47 

19.75 

65.41 

191.51 

145.21 

277.64 

20.34 

63.70 

37.05 

18.09 

94.77 

7.12 

60.95 

39.81 

3.82 

176.92 

14.97 

24.44 

62.56 

224.53 

156.67 

191.49 

30.34 

58.66 

36.66 

20.08 

168.62 

3.79 

26.36 

25.84 

2.12 

86.79 

7.19 

14.78 

37.06 

112.22 

72.34 

89.72 

14.12 

28.52 

17.01 

12.29 

83.02 

10.52 

207.79 

310.21 

283.50 

21.44 

56.60 

223.24 

468.19 

600.09 

813.91 

63.77 

175.63 

118.50 

58.17 

389.71 

22.14 

106.65 

95.49 

18.07 

155.23 

3.39 

158.97 

6.04 

3.82 

28.72 

189.45 

11.60 

21.50 

19.96 

72.13 

1.17 

65.07 

19.19 

1.90 

68.19 

0.20 

6.06 

6.14 

2.85 

13.55 

0.17 

28.66 

131.85 

115.23 

130.22 

41.68 

18.30 

11.18 

11.55 

21.75 

84.08 

9.73 

11.14 

30.79 

93.30 

17.30 

17.15 

33.46 

98.31 

18.48 

17.04 

23.77 

92.71 

19.09 

0.21 

10.16 

55.49 

5.51 

56.88 

109.77 

368.40 

64.61 

250.83 

293.94 

291.25 

310.57 

257.10 

1146.59 

21.51 

25.48 

25.42 

24.92 

122.46 

147.61 

146.07 

119.04 

32.21 

145.87 

0.03 

3.14 

21.78 

143.82 

194.99 

3.87 

54.25 

150.92 

331.59 

7.06 

45.46 

45.76 

166.38 

0.73 

92.37 

488.27 

109.41 

505.68 

545.80 

15.96 

154.82 

173.53 

203.11 

134.40 

599.66 

6.56 

7.22 

6.23 

3.37 

2.39 

8.25 

6.11 

4.97 

5.41 

9.26 

9.26 

5.61 

126.65 

119.07 

114.71 

0.51 

40.94 

141.27 

127.35 

122.64 

113.04 

21.76 

14.00 

0.54 

44.61 

146.24 

117.41 

120.16 

99.72 

22.61 

14.79 

0.47 

49.85 

145.72 

111.69 

116.78 

99.57 

22.99 

15.18 

1.02 

9.28 

6.87 

4.41 

79.28 

1.20 

61.03 

108.43 

104.07 

105.83 

98.54 

0.00 

8.06 

85.92 

70.52 

14.57 

30.79 

27.74 

16.80 

373.99 

1.69 

164.06 

565.07 

471.67 

489.80 

354.02 

85.65 

55.15 

412.08 

166.94 

136.18 

107.95 

100.56 

102.41 

101.16 

70.90 

44.13 

29.65 

42.87 

50.29 

United Kingdom 

339.41 

464.67 

294.78 
111 

231.71 

267.06 

239.17 

1258.21 

 
 
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Member State 

2014 

2015 

2016 

2017 

2018 

2019 

Total 

M11 - Organic farming 

European Union 28 

216.10 

579.20 

951.29 

1159.49 

1333.16 

808.46 

4023.14 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

United Kingdom 

European Union 28 

Belgium 

Bulgaria 

Czechia 

Germany 

Estonia 

Ireland 

Spain 

Italy 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Austria 

Portugal 

Slovakia 

0.51 

43.24 

5.94 

10.82 

35.19 

15.29 

6.94 

26.74 

36.79 

19.03 

8.14 

24.57 

40.46 

26.41 

7.87 

18.17 

39.74 

30.73 

0.04 

0.56 

36.78 

13.60 

28.90 

80.30 

152.18 

91.46 

59.08 

133.72 

164.18 

185.94 

216.96 

129.49 

700.79 

9.81 

1.76 

2.29 

0.27 

39.67 

10.77 

2.88 

111.14 

87.95 

22.39 

13.92 

5.20 

104.14 

111.49 

116.05 

23.37 

13.78 

4.23 

77.74 

110.13 

269.93 

28.06 

14.86 

3.83 

61.24 

32.88 

129.12 

0.58 

48.28 

14.07 

295.31 

349.25 

385.98 

95.94 

175.69 

204.73 

206.48 

152.95 

628.04 

14.19 

48.62 

0.45 

7.50 

14.23 

26.60 

1.40 

34.97 

1.01 

3.83 

3.49 

24.81 

1.82 

22.12 

41.14 

16.09 

23.49 

0.08 

49.72 

49.34 

25.02 

8.43 

5.71 

11.97 

28.56 

37.74 

5.28 

1.60 

19.13 

32.17 

0.30 

25.13 

54.60 

48.10 

22.76 

30.96 

6.60 

12.92 

21.24 

5.06 

6.22 

M12 – Natura 2000 

60.01 

0.31 

18.47 

0.32 

3.77 

3.42 

3.58 

0.04 

0.35 

2.09 

2.15 

69.90 

1.20 

16.72 

0.34 

8.88 

3.42 

2.10 

0.10 

0.27 

2.33 

1.99 

0.99 

18.97 

29.37 

0.29 

16.21 

58.83 

43.93 

22.72 

26.97 

6.85 

13.44 

23.40 

25.67 

7.42 

83.10 

1.45 

17.19 

0.37 

9.29 

3.64 

0.46 

4.37 

6.46 

2.50 

2.21 

0.01 

1.96 

18.96 

27.17 

0.33 

16.10 

0.00 

61.46 

43.38 

21.63 

35.41 

7.22 

12.61 

23.59 

29.60 

9.92 

93.14 

2.63 

17.67 

0.37 

9.48 

3.64 

0.40 

3.26 

15.44 

2.73 

2.34 

0.03 

17.73 

24.73 

27.54 

26.66 

0.00 

7.17 

0.63 

0.00 

7.05 

0.76 
112 

0.00 

7.08 

0.52 

0.60 

7.18 

0.70 

0.68 

18.99 

0.11 

0.32 

12.15 

0.00 

49.18 

38.76 

20.24 

39.25 

0.00 

7.74 

0.33 

37.71 

7.08 

4.54 

73.14 

112.20 

1.01 

57.44 

0.00 

224.62 

184.75 

92.14 

101.77 

26.38 

50.94 

96.80 

98.07 

28.85 

39.82 

306.15 

2.36 

0.01 

0.36 

5.87 

3.69 

0.03 

2.73 

2.43 

2.64 

2.37 

0.00 

9.89 

0.44 

6.86 

0.13 

5.60 

70.05 

1.40 

31.42 

14.12 

6.54 

7.77 

22.52 

9.66 

8.68 

0.04 

96.66 

0.61 

28.48 

2.61 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Member State 

2014 

2015 

2016 

2017 

2018 

2019 

Total 

M13-ANC 

European Union 28 

1698.03 

1706.46 

3321.30 

2737.25 

2663.02 

2359.84  10428.03 

Belgium 

Bulgaria 

Czechia 

Germany 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

United Kingdom 

Source: DG AGRI 

6.91 

42.85 

88.60 

193.24 

3.03 

426.42 

9.71 

28.74 

39.42 

8.02 

127.36 

155.89 

119.75 

0.00 

62.34 

258.85 

31.39 

95.51 

2.29 

32.58 

66.58 

126.21 

118.09 

112.67 

71.98 

41.81 

39.21 

64.29 

4.21 

35.77 

39.97 

3.95 

8.06 

0.42 

125.19 

193.49 

136.31 

207.98 

31.21 

47.08 

97.21 

85.44 

14.47 

2.20 

33.61 

64.84 

140.62 

102.76 

207.73 

99.98 

2.28 

37.09 

69.89 

143.93 

100.42 

226.19 

87.93 

2.27 

37.49 

125.48 

135.44 

87.75 

2.69 

34.87 

128.61 

146.79 

27.07 

139.72 

131.36 

89.91 

80.20 

9.04 

140.77 

326.80 

546.19 

409.02 

686.31 

349.80 

1443.78 

774.91 

794.85 

824.69 

3055.36 

42.62 

42.83 

44.81 

165.36 

164.57 

151.03 

4.46 

37.13 

48.30 

3.89 

7.38 

1.55 

127.25 

194.94 

119.45 

222.30 

31.40 

47.86 

97.55 

19.27 

55.08 

3.17 

55.23 

48.62 

3.88 

8.97 

1.50 

126.01 

198.99 

115.90 

217.05 

31.56 

47.93 

96.31 

55.08 

77.02 

3.16 

42.37 

34.01 

3.82 

4.96 

1.47 

125.37 

195.07 

114.39 

221.62 

31.65 

47.46 

96.21 

49.76 

82.95 

45.90 

97.13 

3.11 

0.00 

45.45 

4.05 

0.13 

1.44 

93.30 

213.78 

104.45 

217.60 

31.82 

37.02 

14.47 

72.31 

1.60 

169.46 

545.25 

15.00 

170.49 

170.91 

15.54 

29.37 

4.95 

503.82 

782.49 

486.05 

868.95 

125.82 

190.32 

387.28 

209.54 

229.52 

Table  15  Summary  of  agricultural  threats  and  opportunities  from  key  EU  species/taxa,  and 
range of possible land management response 

Key 
species 
group 

EU 
or 

Member 
with 

EU 
States 
populations  

Farming 
system(s) 
affected 

Nature  of 
opportunity 

the 

threat  or 

Range  of  possible 
responses  from  land 
managers  

Grey 
Wolf 
(Canis lupus) 

20 
States; 

Member 

BG,  CZ,  DE,  EE, 
EL,  ES,  FR,  HR, 
IT,  LV,  LT,  HU, 
AT,  PL,  PT,  RO, 
SI, SK, SE 

Flocks/herds 
grazing 
pastures 
woodland.  

in 
or 

Livestock predation – mainly sheep 
and  goats  but  also  calves,  colts. 
Reindeer  in  FI  and  SE.  May  also 
prey  on  species  which  can  be 
agricultural pests such as boar. 

illegal 
licensed 

Defensive: 
or 
killing 
hunting: 
abandonment of semi-
natural pastures. 

Brown  Bear 
(Ursus 
arctos) 

15 
States: 

Member 

BG,  EE,  EL,  ES, 
FR, IT, LV, AT, PL, 
RO, SE, SK, SE 

Wide 
range  of 
systems  including 
outdoor  livestock, 
beehives, 
field 
crops,  grassland, 
orchards 
and 
vineyards.  

Adaptive:  shepherding 
dogs, 
with 
guard 
night 
fencing, 
scaring; 
shelters, 
national  or 
regional 
carnivore 
management plans. 

Predation  of  livestock  and  other 
domestic  animals  -  sheep,  goats, 
cattle,  horses,  pigs,  donkeys,  deer 
rabbits,  chickens,  beehives,  dogs. 
In 
food 
sources,  damage  to  field  crops, 
grassland 
bags, 
orchards,  feed  stores,  buildings 
and fences. 

for  other 

searching 

silage 

and 

113 

 
 
  
  
  
  
  
  
  
 
 
Key 
species 
group 

EU 
or 

Member 
with 

EU 
States 
populations  

Farming 
system(s) 
affected 

Nature  of 
opportunity 

the 

threat  or 

Range  of  possible 
responses  from  land 
managers  

Eurasian Lynx 
(Lynx lynx) 

17 Member states 

BG,  CZ,  DE,  EE, 
HR,  IT,  LV,  LT, 
HU,  AT,  PL,  SI, 
SK, FI, SE 

Free 
ranging 
sheep 
flocks 
grazing 
in  open 
also 
pastures, 
reindeer  in  FI  and 
SE. 

Livestock predation.  

ES, PT 

Iberian  Lynx 
(Lynx 
pardinus) 

Wolverine 
(Gulo gulo) 

FI, SE 

attacks 
Sheep 
most 
cause 
economic 
losses, 
but poultry attacks 
are more frequent. 

Free 
reindeer herds. 

ranging 

Livestock predation. 

Livestock predation. 

goose 

Greylag 
widespread, 
mainly  in  BE,  DK, 
DE,  HU,  NL,  AT, 
FI, SE, UK 

Grass  and  arable 
(winter 
crops 
field 
cereals, 
beans, 
oilseed 
rape, root crops). 

Grazing/trampling 
of 
crops throughout year. 

different 

Defensive: 
hunting; 
unpalatable crops. 

licensed 
growing 

Greylag 
Goose  (Anser 
anser) 
and 
Barnacle 
Goose 
(Branta 
leucopsis) 

Red-breasted 
Goose 
(Branta 
ruficollis) 

(Grus 

Crane 
grus) 

Barnacle 
Goose 
winters  in  DE,  IE, 
NL, UK 

Arable weeds  Mainly 

in  south-
eastern Europe, in 
traditional, 
extensively 
managed 
crops 
mosaic 
landscapes. 

arable 
in  HNV 

Wild 
pollinators 

All Member States 

crops 
Arable 
cereals, 
(winter 
rape, 
oilseed 
maize,  sunflower) 
and 
vegetable 
crops. 

Arable, mixed. 

Arable 
crops 
cereals, 
(except 
rice  and  soya); 
fruit,  legume  and 
some 
vegetable 
crops. 

Feeding on crops.  

Decline  in  extensively  managed, 
low input arable cropping. 

Use of broad spectrum pesticides. 

Lack  of  habitat 
feeding,  breeding 
wintering, near to target crops. 

suitable 
and 

for 
over-

scaring, 

Adaptive: 
sacrificial  crops,  non-
grazing 
disturbance 
areas, 
scaring 
elsewhere. 

Defensive:  Herbicide 
use on crops and field 
margins. 

Adaptive: 
conservation 
crops/margins 
herbicides). 

arable 
(no 

Adaptive: 
field 
margins,  hedgerows, 
flower-rich 
strips, 
species-rich grassland, 
heathland  and  scrub 
and  woodland  edges 
managed 
without 
pesticides. 

Wild 
bio-
logical control 
agents  

All Member States 

Arable  and 
crops. 

fruit 

Source: evaluation support study on biodiversity177  

177  See footnote 11. 

114 

 
 
 
 
 
 
 
 
 
 
                                                      
Table 16 Member State strategic priorities for biodiversity and CAP measures implemented 

Priority 
identified 
NBSAP or PAF 

in 

CAP measures 

DE 
(BW) 

FR 
(CVdL) 

HR 

HU 

IE 

LV  NL 

PT 

RO 

SK 

and 
Protection 
of 
maintenance 
pasture 
and 
grassland  habitats 
and species 

Ruminant  VCS  with 
density 
stocking 
limits;  ANC;  AECM 
support  for  grazing, 
cutting and mowing 

Protection 
maintenance 
forest 
and species 

and 
of 
habitats 

Agroforestry, 
and 
afforestation 
forest  environment 
measures 

Use  of  M7.1  and 
M12.1 

Use  of  M7.1  and 
M12.2 

Adequate  HNV  map 
plus  targeted  CAP 
measures  

M11,  AECM 
input options 

low 

Development  and 
of 
maintenance 
the  Natura  2000 
network 
(agriculture) 

Development  and 
maintenance 
of 
the  Natura  2000 
network (forestry) 

and 
Protection 
maintenance 
of 
high  nature  value 
farmland 

of 
Minimisation 
negative  external 
of 
impacts 
on 
agriculture 
biodiversity 
(e.g. 
input reduction) 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Tackling 
species  

invasive 

7 

GAEC 
AECM, M4.4 

option, 

X 

X 

X 

X 

X 

X 

X 

X 

X 

VCS, M10.2 

M4.4, AECM options 

Preserving 
managing 
and 
resources 

and 
plant 
genetic 

Restoration 
maintenance 
peatlands 
wetlands 

and 
of 
and 

Farmland birds 

AECM 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Source:  evaluation  support  study  on  biodiversity178  on  the  basis  of  National  Biodiversity  Strategies  and  Actions; 
Prioritised Action Frameworks for Natura 2000; Rural Development Programmes 

Legend:  

  Green: uses most/all CAP measures relevant to priority.  
  Red: uses few/none.  
  White:  priority  not  identified  in  the  case  study  National  Biodiversity  Strategies  and  Actions  or  Prioritised 

Action Frameworks for Natura 2000. 

178  See footnote 11. 

115 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Table 17 Summary of the theoretical coherence assessment of CAP instruments and measures under general objective related to biodiversity 

Measure 

FAS 

XC 

BPS/ 
SAPS 

CD 

PG 

ESPG  EFA  VCS 

Redi
st. 

SFS 

Cott
on 

F/V 
OPs 

M1 

M2 

M3 

M4 

M5 

M7 

M8 

M10  M11  M12  M13  M15  M16  M19 

 ER 

 PC 

FAS 

XC 

BPS/SAP
S 

CD 

PG 

ESPG 

EFA 

VCS 

Redist. 

SFS 

Cotton 

F/V OPs 

M1 

M2 

M3 

M4 

M5 

M7 

M8 

M10 

M11 

M12 

M13 

M15 

M16 

M19  
Source: Study on biodiversity (based on expert judgement)  
Legend: Green=positive; red=conflict Amber=  mixed i.e. potential synergies, but also conflicts; blue= neutral,  XC=cross-compliance referring to SMRs 2 and 3 and GAEC 7, ER= eligibility rules, PC 
permanent crops, F/V Ops fruit and vegetables operational programmes 

116 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table  18  Coherence  of  CAP  instruments  and  measures  with  the  water-related  specific 
objectives for ‘sustainable management of natural resources and climate action’ 

Sustainable Management of Natural Resources and Climate Action 

CAP measures and instruments 

Improve water 
(qualitative) 
management, 
including fertiliser 
and pesticide 
management 

Increase 
efficiency in 
water use by 
agriculture 

Pursue climate 
change 
mitigation and 
adaptation 

Provide 
public 
goods 

+1 
+1 

+1 

M 
+1 

+1 

+1 

0 

+1 
+1 

+1 

M 
+1 

+1 

+1 

0 

N/A 

N/A 

0 
+1 

+1 

M 
M 
M 

0 
+1 

+1 

M 
M 
M 

+1 

+1 

M 
+1 

+1 
+1 

+1 
+1 

Horizontal measures 
Cross-compliance 
Farm advisory systems 
Pillar II measures 
Knowledge transfer and 
capacity-building measures (M1, 
M2 and M16) 
Investment measures (M4) 
Forestry measures (M8, M15) 
Land management measures 
(M10, M12 and M15) 
Organic farming (M11) 
Areas facing natural constraints 
(M13) 
LEADER (M19) 
Pillar I measures 
Basic payments 
Greening – Crop diversification 
Greening – Ecological Focus 
Areas (EFAs) 
Greening – permanent grassland 
Voluntary Coupled Support (VCS) 
CMO sector-specific support 
Source: Study on water (based on EU legislation, literature review and case-study reports) 

M 
M 
N/A. 

M 
M 
M 

0 
+1 

0 
+1 

M 
+1 

N/A 

N/A 

+1 

+1 

+1 

+1 

+1 

+1 

0 

0 

Legend 

- Red (-1) = contradictions or competition; 
- Blue (M) =mixed, depends on Management Authorities’ implementation choices; 
- Yellow (0) = neutrality, or no particular association; and  
- Green (+1) = a complementary or synergistic relationship.  

117 

 
 
 
 
Table  19  Coherence  of  CAP  measures  with  the  Birds  and  Habitats  Directives  and  actions 
under Target 3 of the EU Biodiversity Strategy 

Biodiversity strategy Target 3 

Measure 

& 

Birds 
Habitats 
Directives 

8: 

Action 
Enhance 
CAP  direct 
payments 

Action  9:  Better 
target 
Rural 
Development 

Action  10: 
genetic 
diversity 

11: 

Action 
Encourage 
forest 
conservation 

Action 
Biodiversity 
measures 
forest plans 

12: 

in 

Horizontal measures - Regulation (EU) No 1306/2013 

FAS 

Cross-compliance 
(SMRs and GAEC) 

M 

+1 

M 

+1 

Direct Payment Regulation - Regulation (EU) No 1307/2013 

BPS & SAPS 

Redistributive 
payment 

Greening: 
diversification 

Crop 

Greening: PG ratio 

Greening: ESPG  

Greening: EFAs 

VCS 

SFS 

Crop-specific 
payment for cotton 

M 

M 

M 

+1 

+1 

M 

M 

M 

- 

M 

M 

+1 

+1 

+1 

+1 

M 

M 

- 

+1 

0 

+1 

0 

NA 

0 

+1 

0 

+1 

+1 

NA 

+1 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

+1 

0 

0 

0 

0 

0 

0 

0 

0 

0 

+1 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

Common Market Organisation - Regulation (EU) No 1305/2013 

Operational 
programmes  in  the 
fruit  and  vegetables 
sector 

- 

- 

0 

NA 

NA 

NA 

Rural Development Regulation - Regulation (EU) No 1305/2013 

M1 
Knowledge 
and 
transfer 
information actions 

M2 
services, 
management 
farm relief services 

Advisory 
farm 
and 

M3 Quality schemes 

M4  Investments  in 
physical assets 

M5  Restoring  and 
prevention  actions 
natural 
after 
disasters 

M 

M 

M 

M 

M 

M 

M 

0 

0 

0 

+1 

+1 

+1 

+1 

+1 

+1 

+1 

NA 

NA 

+1 

NA 

NA 

NA 

+1 

0 

M 

M 

M 

M 

M 

118 

 
 
 
 
 
Biodiversity strategy Target 3 

& 

Birds 
Habitats 
Directives 

8: 

Action 
Enhance 
CAP  direct 
payments 

Action  9:  Better 
target 
Rural 
Development 

Action  10: 
genetic 
diversity 

11: 

Action 
Encourage 
forest 
conservation 

Action 
Biodiversity 
measures 
forest plans 

12: 

in 

M 

M 

+1 

+1 

M 

+1 

+1 

+1 

+1 

0 

NA 

0 

0 

M 

0 

NA 

0 

0 

M 

M 

+1 

+1 

0 

+1 

NA 

+1 

+1 

+1 

NA 

+1 

+1 

+1 

+1 

NA 

+1 

+1 

NA 

M 

NA 

NA 

NA 

+1 

+1 

+1 

NA 

+1 

M 

NA 

NA 

NA 

+1 

+1 

+1 

NA 

Measure 

M7  Basic  services 
and village renewal 

M8 
investments 

Forest 

Agri-

M10 
environment-
climate 

M11 
farming 

Organic 

M13 ANC 

M12  Natura  2000 
and WFD payments 

Forest-

M15 
environment-
climate 

M16 Cooperation 

M19 LEADER  

Source: evaluation support study on biodiversity179 

Note: Assessments are only made where the measure has the potential to have an effect 

Actions under Target 3:  

  Action  8:  Enhance  CAP  direct  payments  to  reward  environmental  public  goods  such  as  crop  rotation  and 
permanent pastures; improve cross-compliance standards for GAEC (Good Agricultural and Environmental 
Conditions) and consider including the Water Framework in these standards. 

  Action  9:  Better  target  Rural  Development  to  biodiversity  needs  and  develop  tools  to  help  farmers  and 

foresters work together towards biodiversity conservation. 

  Action 10: Conserve and support genetic diversity in Europe's agriculture.  
  Action 11: Encourage forest holders to protect and enhance forest biodiversity. 
  Action 12: Integrate biodiversity measures such as fire prevention and the preservation of wilderness areas in 

forest management plans.  

Legend:  
-1 (red) = contradicts/competes;  

+1 (green) = positive or synergistic;  

- (white): inconclusive assessment;  

0 (blue) = neutral/no particular association;  

M (amber) = mixed;  
NA (white): not applicable. 

179  See footnote 11. 

119 

 
 
 
 
 
 
 
 
 
                                                      
Table 20 Coherence of CAP instruments and measures with the EU soil-related objectives180 

EU environmental and climate policies 

Cross-cutting policies (non-binding) 

7th Environmental Action Plan (7th EAP) 

Soil Thematic Strategy  

CAP instrument or measure 

Designed to address 
sustainable soil 
management(1) 

With potential 
direct effects on 
sustainable soil 
management (2) 

With potential indirect 
effects on sustainable 
soil management (3) 

 synergetic 

 synergetic 

 synergetic 

 synergetic 

 neutral/limited 

 neutral/limited 

Diffuse pollution & water management policies (binding) 

Water Framework Directive 

 synergetic 

 synergetic 

 neutral/limited 

Sewage Sludge Directive  

 neutral/limited 

 neutral/limited 

 neutral/limited 

Floods Directive 

Nitrates Directive 

 synergetic 

 synergetic 

 neutral/limited 

 neutral/limited 

 mixed/conflicting 

 neutral/limited 

Sustainable Use of Pesticides Directive 

 synergetic 

 mixed/conflicting 

 neutral/limited 

Biodiversity & nature protection policies (binding) 

Habitats and Birds Directive 

EU Biodiversity Strategy  

Air & climate policies (binding) 

NEC Directive  

LULUCF Decision. 

Effort Sharing Decision 

 synergetic 

synergetic 

 synergetic 

 synergetic 

 synergetic 

 synergetic 

 neutral/limited 

synergetic 

neutral/limited 

 mixed/conflicting 

 neutral/limited 

 mixed/conflicting 

 neutral/limited 

 mixed/conflicting 

 neutral/limited 

Source: evaluation support study on soil181 (adaptation) 

Notes: 
(1)  GAECs 4, 5 and 6; Greening – Crop diversification; M8.1, M8.2, M8.5, M10.1, M11,  
(2)  GAECs 1 and 3 and SMR1 and SMR10, Greening  – EFAs and the maintenance of permanent grassland and the 

fruits and vegetables environmental measures; M4.1, M4.3, M4.4;  

(3)  Other sector-specific measures, M1, M2, M5, M8.3, M8.4, M12, M15.1 and EIP-AGRI 

180 The Fertilising Product Regulation 2019/1009 does not yet apply,  therefore analysis should not take it 

into consideration. 

181  See footnote 12. 

120 

 
 
 
  
  
  
  
  
  
 
 
                                                      
Table  21  Coherence  of  CAP  instruments  and  measures  with  the  key  EU  key  water  and 
environmental policies and strategies 

CAP measures and instruments 

Other EU Policies 

WFD 

Nitrates 
Directive 

SUPD 

Nature 
legislation 

Biodiversity 
Strategy 

+1 
+1 

Horizontal measures 
Cross-compliance 
Farm advisory systems 
Pillar II measures 
Knowledge transfer and 
capacity-building measures (M1, 
M2 and M16) 
Investment measures (M4 and 
M8) 
Land management measures 
(M10, M12 and M15) 
Organic farming (M11) 
Areas facing natural constraints 
(M13) 
LEADER (M19) 
Basic services and natural 
disasters (M5, M7) 
Pillar I measures 
Sector-specific support under 
CMO 
Basic payments 
Greening – Crop diversification 
Greening – Ecological Focus 
Areas (EFAs) 
Greening – permanent grassland 
Voluntary Coupled Support 
(VCS) 
Other non-CAP policies  
Other non-water-targeted 
measures outside CAP (e.g. 0-
tariff import) 
Source: evaluation support study on water182 

+1 

M 

+1 

+1 

+1 

+1 

+1 

+1 

0 
+1 

+1 

M 

M 

-1 

+1 
+1 

+1 

+1 

+1 

+1 

0 

0 

0 

0 

0 
+1 

+1 

+1 

0 

-1 

0 
0 

+1 

0 

+1 

+1 

0 

0 

0 

0 

0 
0 

0 

0 

0 

0 

+1 
0 

0 

+1 

+1 

+1 

+1 

+1 

+1 

0 

0 
0 

+1 

+1 

0 

0 

+1 
0 

0 

+1 

+1 

+1 

+1 

+1 

+1 

0 

0 
+1 

+1 

+1 

0 

0 

Legend: 
Red (-1) = contradiction or competition;  
Blue (M) =mixed, depends on Managing authorities implementation choices 
Yellow (0) = neutrality, or no particular association; and  
Green (+1) = a complementary or synergistic relationship. 

182  See footnote 13. 

121