Organic farming in the EU : gaps and inconsistencies hamper the success of the policy. Special report 19, 2024.
Date: 2024-10-01
Institutions: European Court of Auditors
Subjects: EU Member State, EU policy, EU strategy, agricultural production policy, audit, common agricultural policy, financing, food production, fund (EU), organic farming, organic product, performance audit, report

EN 

2024 

19 

Special report  Organic farming in the EU 

Gaps and inconsistencies hamper the success of 
the policy 

 
 
 
2 

Paragraph 

I-X 

01-12 

01-04 

05-06 

07-10 

11-12 

13-17 

18-77 

18-35 

19-24 

25-31 

32-35 

36-59 

37-43 

44-51 

52-59 

Contents 

Executive summary 

Introduction 

Organic farming as a more sustainable agricultural practice 

Organic farming is an integral part of the organic sector 

EU policy for the organic sector 

Roles and responsibilities 

Audit scope and approach 

Observations 

Gaps in EU and national policies for the organic sector 

The EU policy for the organic sector is weakened by gaps in the strategic 
framework 

Weaknesses in national policies hamper the development of the EU organic 
sector 

Member states only partially addressed the specific needs of their organic 
sector when programming CAP support 

Area increased, but it is still a challenge to integrate the 
objectives of organic farming in the CAP 

CAP support helped increase the organic area, but environmental benefits 
were not always guaranteed 

Member states did not always ensure that CAP support for organic farming 
leads to organic production 

Member states did not target CAP funding sufficiently well to further 
develop the organic sector 

Data constraints limit sound policy making for the organic sector 

60-77 

The impact of the CAP support for organic farming cannot be assessed 

Existing EU tools are not fit for analysing the impact of organic farming 

Fewer statistical variables collected on the organic sector 

Conclusions and recommendations 

61-66 

67-71 

72-77 

78-82 

 
 
Annex – Consumption of organic products in member 
states 

3 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I Organic farming is an agricultural method to produce food using natural substances 
and processes, contributing to greater biodiversity and less water, air, and soil 
pollution. The Commission considers it a key tool for making agriculture more 
sustainable and set the target of having 25 % of the EU's agricultural land organically 
farmed by 2030 – a significant jump from 10.5 % in 2022. In the 2014-2022 period, 
farmers received around €12 billion in support of organic farming practices under the 
common agricultural policy. 

II Our audit assessed the design, implementation and monitoring of EU support for 
organic farming. It covered the 2014-2022 period, and where relevant, we also 
checked the provisions and programmes in place for 2023-2027. We carried out this 
audit in light of the significant amount of EU spending on organic farming. We expect 
our report to contribute to the EU’s policy for the organic sector and to the 
Commission’s legislative proposals for the post-2027 CAP, which are planned in 2025. 

III Overall, we concluded that there were gaps in both EU and national policies for 
the organic sector. CAP funds were used to increase the organically farmed area, 
without sufficiently taking into account the environmental and market objectives set in 
the EU’s policy for organic farming. The impact of the policy could not be assessed due 
to data constraints. 

IV We found that there are gaps in the strategic framework of the EU policy for the 
organic sector. The EU action plans, which the Commission uses to define the strategy 
for the organic sector, lack important elements. Although the current plan is an 
improvement on the previous one, it still neither includes quantifiable targets for the 
defined objectives and actions, nor a way to measure progress. The only target for the 
organic sector is the non-binding 25 % target for the organically farmed land, which 
only focuses on increasing the area. There is no strategy and there are no targets for 
the organic sector beyond 2030. 

V The extent of the development of organic farming, and ambitions to grow it 
further, differ greatly in the member states. While all but three of the EU-27 now have 
organic action plans in place, there is a risk that these will not be sufficient to enable 
the 25 % EU target to be reached by 2030. To reach this target, the current annual 
increase in organic farming would need to double. In member states where the organic 
sector is underdeveloped, national action plans have the potential to play a key role in 
driving development. However, the low quality of these plans weakens their impact. 

 
 
5 

VI The common agricultural policy is the main source of funding for developing 
organic farming in the EU. We found that while this support helped to increase the 
area of organically farmed land, integrating the environmental and market objectives 
of EU policy for organic farming into EU spending remains a challenge. 

VII The provision of EU support for organic farming is based on expected 
environmental benefits, but these are not always guaranteed. Rules for organic 
farming were not applied consistently in the four member states we visited, in 
particular for crop rotation and animal welfare. While integrating the voluntary 
principles of organic farming into EU spending could reinforce its positive 
environmental impact, we found that the member states rarely did so. 

VIII One objective of EU policy is that organic farming produces a wide variety of 
foods to supply the market for sustainable products. A well-developed market acts as 
an additional incentive for farmers to convert to organic farming and facilitates long-
term growth. Despite this, member states did not target CAP funding sufficiently well 
to strengthen the farmers’ position in the value chain and further develop the organic 
sector. 

IX The Commission monitors EU spending for organic farming and the size of the 
supported area. However, the impact of this support cannot be assessed because the 
existing tools are not fit for purpose. The Commission also lacks data on how EU 
spending supports the development of the organic sector beyond organic farming, 
especially considering that less data is collected now than prior to 2021. 

X Based on our findings, we recommend that the Commission: 

o 

o 

o 

strengthen the EU strategic framework for the development of organic sector, 
establishing a way to measure progress and setting a vision beyond 2030; 

better integrate environmental and market objectives into CAP support and 
better target post-2027 funds to develop the organic sector; 

ensure the availability of relevant data to assess the development of organic 
farming and its impact on environment and climate by using existing tools and 
information more effectively. 

 
 
6 

Introduction 

Organic farming as a more sustainable agricultural practice 

01 Almost 40 % of EU land is used for agriculture1. While its primary role is to 
provide food, agriculture also contributes to the development and social cohesion of 
rural areas. Agriculture depends on the sustainable use of natural resources, while also 
being a source of environmental and climate pressures, leading to the pollution of soil, 
water and air, and the over-exploitation of natural resources 2. 

02 Since the 1990s, the EU has encouraged the use of more environmentally 
sustainable farming practices. Of these, organic farming remains the only agricultural 
production method that is standardised and regulated at EU level. The aim of organic 
farming is to produce food using natural substances and processes, in line with 
principles and rules set out in EU legislation – see Figure 1. 

1  Eurostat, Farms and farmland in the European Union – statistics, 2020. 

2  EEA, SOER 2020, p. 295 and 314. 

 
 
 
Figure 1 – Principles and rules of organic farming 

7 

PRINCIPLES:

Respect nature’s 
systems and cycles

Sustain and enhance 
soil health and quality

Preserve natural 
landscape elements

Use energy and natural 
resources (water, soil, 
organic matter, and air) 
responsibly

Restrict the use of 
external inputs

Produce a wide variety 
of high-quality food

Rules for LIVESTOCK:

Rules for CROPS:

high animal welfare 
standards respecting 
species-specific needs

severely restricted use of 
antibiotics

no synthetic pesticides or 
fertilisers

no genetically modified 
organisms

organic or in-conversion 
feed, primarily from the 
agricultural holding

minimum spacing 
requirements and access 
to outdoor areas and 
pasture

organic seeds and plant 
reproductive material

multiannual crop 
rotation including 
leguminous crops and 
other green manure crops

no growth promoters or
force feeding

clear separation 
between conventional 
and organic units on 
mixed farms

preventive and 
precautionary measures 
to avoid contamination

clear separation 
between conventional 
and organic units on 
mixed farms

Source: ECA based on Regulation (EU) 2018/848 on organic production and labelling of organic products. 

 
 
 
8 

03 Since it is based on a strict limitation of synthetic pesticides and fertilisers, 
organic farming is considered to be a more environmentally sustainable alternative to 
conventional agriculture by design, contributing to greater biodiversity and less water, 
air, and soil pollution3. Crop rotation and other management practices used on organic 
farms can improve soil health and fertility, as well as the soil’s capacity to retain water 
and capture carbon, contributing to climate resilience. 

04 In 2022, around 17 million hectares were farmed organically in the EU, 
representing 10.5 % of the total utilised agricultural area4. While in the EU the share of 
organic agricultural area has constantly increased since 2014, the uptake of organic 
farming varied significantly at member state level, ranging from 0.6 % in Malta to 
25.7 % in Austria, as shown in Figure 2. 

3  Smith OM, Cohen AL, Rieser CJ, Davis AG, Taylor JM, Adesanya AW, Jones MS, Meier AR, 
Reganold JP, Orpet RJ, Northfield TD and Crowder DW, Organic Farming Provides Reliable 
Environmental Benefits but Increases Variability in Crop Yields: A Global Meta-Analysis, 
September 2019. 

4  Eurostat, Developments in organic farming. 

 
 
 
9 

Figure 2 – Four member states account for almost 60 % of the EU’s 
organic agricultural area 

Area under 
organic farming 
(million ha)

Organic farming 
share of the total 
utilised 
agricultural area

0

0.5

1

1.5

2

2.5

3

56 % 
of the organic 
area in the EU

10.1 %

10.8 %

18.1 %

9.8 %

17.2 %

19.3 %

25.7 %

5.1 %

19.9 %

16.0 %

3.9 %

15.0 %

6.3 %

15.9 %

11.4 %

9.3 %

13.7 %

23.4 %

8.9 %

2.2 %

7.6 %

2.2 %

4.4 %

11.1 %

6.2 %

6.3 %

0.6 %

France

Spain

Italy

Germany

Greece

Portugal

Austria

Romania

Sweden

Czechia

Poland

Finland

Hungary

Latvia

Denmark

Lithuania

Slovakia

Estonia

Croatia

Bulgaria

Belgium

Ireland

Netherlands

Slovenia

Luxembourg

Cyprus

Malta

Luxembourg
Cyprus

Malta

0

1

2

3

4

5

6

7

8

(thousand ha)

NB: 2020 data used for Austria. 

Source: ECA based on Eurostat 2022 organic farming statistics (extracted on 25 June 2024). 

 
 
 
10 

Organic farming is an integral part of the organic sector 

05 Organic farming supplies organic products to the market, to respond to consumer 
demand for more sustainable food. As such, it is at the core of the organic sector, 
which encompasses all actors and processes from the farm to the consumer – see 
Figure 3. The development of organic farming is closely linked to the development of 
the organic sector. 

Figure 3 – The organic sector 

Crops

Seeds and other 
planting material

Livestock

Source: ECA. 

06 In 2022, organic products accounted for around 4 % of the total EU food market, 
generating €45 billion in sales5. Between 2014 and 2022, EU sales of organic products 
more than doubled6. However, significant differences remain between member states 
in terms of the consumption of organic products. In 2022, the range was from €2 per 
capita spent in Romania to €365 per capita in Denmark – see Annex. These differences 

5  FIBL statistics for organic retail sales, and Statista data for food sales in EU-27 (last 

extracted on 12 April 2024). 

6 

Ibid. 

 
 
 
 
11 

highlight the uneven development of the market for organic products across the EU 
and the link to purchasing power in the member states. 

EU policy for the organic sector 

07 The development of organic farming is driven by the principles, rules and 
objectives set in the EU policy for the organic sector. This policy is composed of three 
layers: a legal framework, a strategic framework, and a financial framework. In place 
since 1991, the policy has evolved over time – see Figure 4. 

 
 
Figure 4 – Evolution of EU policy for the organic sector 

LEGAL

STRATEGIC

FINANCIAL

12 

Organic production is 
regulated at EU level 
for the first time: 
Council Regulation (EEC) 
No 2092/91 on organic 
production of 
agricultural products 
and indications

Legal basis updated: 
Council Regulation (EC) 
No 834/2007 on organic 
production and labelling 
of organic products. 
Applicable from 1 
January 2009

Legal basis updated: 
Regulation (EU) 
2018/848 on organic 
production and labelling 
of organic products. 
Applicable from 1 
January 2022

1991

1994

2004

2007

2014

2018

2020

2021

2023

2027

2030

Source: ECA. 

From 1994: no specific 
measure. EU support is 
provided through 
commitments to adopt 
more environmentally 
friendly agricultural 
practices 
(agri-environment 
commitments)

1st EU action plan: 
European action 
plan for organic food 
and farming

2nd EU action plan: 
Action plan for the 
future of organic 
production in the EU

From 2014: EU support is 
provided through a 
specific measure for the 
development of organic 
farming

3rd EU action plan: 
Action plan for the 
development of 
organic production

Farm to fork strategy 
and biodiversity 
strategy to 2030, 
establishing the target 
of 25 % of agricultural 
area to be organically 
farmed by 2030

End of 3rd EU action plan

From 2023: no specific 
measure. EU support is 
provided through 
agri-environment and 
climate commitments, 
payments for specific 
agricultural sectors or 
schemes for the climate, 
the environment and 
animal welfare

 
 
 
13 

08 The Regulation on organic production and labelling of organic products (the 
Organic Regulation) provides the legal basis for organic farming and regulates the rest 
of the organic sector supply chain, from farmers to retailers (see Figure 3). It 
establishes the objectives and principles of organic production, and the rules organic 
farmers and other operators must follow to receive organic certification. 

09 The Commission complemented the legal framework of the organic sector with 
three successive action plans, published in 2004, 2014 and 2021. These action plans 
were also intended to define the EU strategy for organic farming7. In May 2020, the 
Commission published the farm to fork strategy and the EU biodiversity strategy 
for 2030, implementing the European Green Deal. Both strategies established a 
strategic goal to have 25 % of the EU’s agricultural land organically farmed by 2030. 
Although non-binding, the target indicates that organic farming has a role to play in 
meeting the EU’s environmental and climate objectives. 

10 Financial support for the development of organic farming has mainly been 
provided through the common agricultural policy (CAP). In the 2014-2022 period, 
farmers received almost €12 billion of EU support from the European Agricultural Fund 
for Rural Development (EAFRD) to convert to organic farming or to maintain organic 
farming practices. In addition: 

o 

o 

in the 2014-2022 period, the European Agricultural Guarantee Fund provided 
around €60.6 million to develop organic production in the fruit and vegetables 
sector through producer organisations; 

in the 2014-2020 period, around €45 million of EU financial support was provided 
for research and innovation in organic farming through Horizon 2020; in the 
2021-2027 period, 30 % of the Horizon Europe funds for agriculture, forestry and 
rural areas are intended for topics directly or indirectly linked to the organic 
sector; 

o 

in the 2016-2023 period, around €140 million was provided to promote organic 
products through the EU’s agri-food promotion policy8; and 

7  Commission Staff Working Document “Impact assessment accompanying the document 
Proposal for a Regulation on organic production and labelling of organic products”, 
SWD/2014/065 final, March 2014. 

8  Commission selection decisions for the EU agri-food promotion policy for the 2016-2023 

period. 

 
 
 
14 

o 

in the 2023-2027 period, member states have planned to allocate around 
€14.7 billion to support organic farming in their CAP strategic plans9. 

Roles and responsibilities 

11 The Commission, through the Directorate-General for Agriculture and Rural 
Development (DG AGRI), in consultation with other directorates-general, sets the 
overall EU policy for the organic sector. The Commission approves the member states’ 
rural development programmes for the CAP and provides member states with strategic 
guidelines on the EU’s organic policy. Together with DG AGRI, Eurostat collects, 
validates, and publishes data on the organic sector. The Joint Research Centre provides 
science-based knowledge to monitor and assess the impact of EU policies. 

12 Based on their specific situations and needs, member states are responsible for 
establishing the national objectives for organic farming and the organic sector, and for 
programming adequate EU and national financial support to meet these objectives. 
Member states programme and implement relevant EU support through their rural 
development programmes. 

9  Commission, Approved 28 CAP strategic plans (2023-2027), p. 74, June 2023. 

 
 
 
 
 
15 

Audit scope and approach 

13 We examined the design, implementation and monitoring of EU support for 
organic farming. We asked whether the Commission and the member states had: 

o 

o 

designed a sound policy for the organic sector to boost organic farming; 

used CAP funds effectively to support the environmental and market objectives of 
organic farming; and 

o 

appropriately monitored and evaluated the impact of the EU policy. 

14 In light of our recent special report 04/2019 on the control system for organic 
products and special report 25/2023 on EU aquaculture policy, we excluded organic 
farming controls and certification, and the organic aquaculture sector from our scope. 
Considering their specific nature, we also excluded the organic beekeeping sector, 
research and innovation in organic farming, and the EAGF for supporting organic 
production in the fruit and vegetables sector (see paragraph 10). 

15 We carried out this audit given the 25 % organic farming target and the almost 
€12 billion of EU support in the 2014-2022 period for converting to or maintaining 
organic farming practices. We expect our findings and recommendations to contribute 
to developing the EU policy for organic farming and to provide input for the 
Commission’s legislative proposals for the post-2027 CAP, which are planned in 2025. 

16 Our audit covered the 2014-2022 period. Where relevant, we also checked the 
provisions and programmes in place for 2023-2027. We obtained evidence from: 

o  meetings with representatives from the Commission (DG AGRI, Eurostat and the 

Joint Research Centre); 

o 

o 

o 

a review of relevant data and documents, including specific legislation and 
studies, impact assessments and audit reports, as well as evaluations and 
monitoring information; 

the analysis of statistical data and funding management data for the organic 
sector in the EU; 

interviews with national and regional authorities, and structured meetings with 
representatives from the organic sector; 

 
 
16 

o 

o 

on-the-spot visits to 26 organic farms which had received EU financial support 
(between six and seven farms in each visited member state); 

a study visit to Denmark, a member state that has provided policy support for 
organic farming since 1987, and which has a well-developed market for organic 
products; 

o 

a panel discussion with scientific, policy, and organic farming experts. 

17 We carried out audit visits to four member states: Romania, Poland, Austria and 
Italy. These countries were selected to cover different shares of organic area and 
potential for further development (see Figure 5). In Italy, we selected the regions of 
Campania and Sicily to look at the regional implementation of CAP support. 

 
 
Figure 5 – Organic farming in the audited member states 

Area in thousand ha

Utilised agricultural area 

Organically farmed area

Organic farming share

= 1 000 organic farmers
(the numbers have been rounded)

Italy

2 349.5

83

18.1 %

12 950.4

Countries ordered by decreasing 
organically farmed area

Campania

516.5

101.8

4

Sicily

1 344.5

387.2

11

17 

19.7 %

28.8 %

Austria

2 599.5

680.0

26

Romania

Poland

25.7 %

5.1 %

3.9 %

12 677.6

14 197.9

644.5

13

554.6

21

Source: ECA based on 2022 Eurostat statistics on organic farming (extracted on 25 June 2024), and Bio in 
Cifre 2023 for Sicily and Campania. 2020 data used for Austria. 

 
 
 
 
 
18 

Observations 

Gaps in EU and national policies for the organic sector 

18 We looked at the policy set up by the Commission and member states to support 
the development of organic farming10. We expected to find that: 

o 

the Commission designed a comprehensive EU policy for the organic sector; 

o  member states established national policies to support organic farming; 

o  member states programmed CAP funds in line with the specific needs of their 

own organic sector. 

The EU policy for the organic sector is weakened by gaps in the strategic 
framework 

19 According to the Commission, the EU organic action plans provide the EU 
strategic framework for the organic sector. However, we found that the 2014-2020 
action plan did not include any goals for the organic sector. It also lacked key elements, 
such as: 

o 

quantifiable targets for the plan’s specific objectives and actions; 

o  milestones, and a timeline for implementing the actions; 

o 

o 

o 

indicators to monitor progress; 

clearly defined roles and responsibilities; and 

financial allocations. 

20 In the 2021-2027 action plan, the Commission indicated that the actions under 
the previous plan had been implemented, without specifying which activities had been 
carried out and what had been achieved. In the absence of quantified targets, 
monitoring indicators, and an evaluation, the actual impact of the 2014-2020 action 
plan remains unknown. 

10  Better regulation toolbox, 2021. 

 
 
 
19 

21 In 2020, the strategic goal for the organic sector was defined by the non-binding 
commitment to have 25 % of the EU’s agricultural land under organic farming by 2030 
(see paragraph 09). The Commission set up the 2021-2027 action plan to support the 
achievement of this goal. The action plan defined specific objectives to improve 
organic farming’s contribution to sustainability, to stimulate demand and ensure 
consumer trust, and to stimulate conversion and reinforce the entire value chain. 

22 We found that the 2021-2027 plan represents an improvement compared with 
the previous one. It provides more detail about the specific activities to be 
implemented within each action. The responsibilities have been shared out between 
the Commission, member states and other stakeholders. The Commission set up a 
progress report every 6 months to follow up on the activities carried out. 

23 Despite the progress made, the plan still lacks quantifiable targets for the three 
specific objectives and also lacks the means to monitor progress achieved through the 
actions proposed. In the absence of these elements, its contribution to the 
development of the organic sector will be difficult to assess. The sustainability of 
organic farming over time depends on the overall development of the organic sector. A 
well-developed sector would provide farmers the economic incentives for organic 
farming. However, the 25 % target only refers to the area that is to be farmed 
organically, with no strategic goals for the organic sector. There is no strategic vision 
for organic farming or the organic sector beyond 2030 to provide stability and a long-
term perspective for the value chain. 

24 In addition to the specific objectives in the action plans, the legal framework also 
defines environmental and market objectives for organic production – see Figure 6. 
However, the Commission sees the objectives in the Organic Regulation as inherent 
characteristics of the organic food production system rather than as actual objectives. 
They are therefore neither monitored nor specifically addressed in the strategic 
framework. 

 
 
Figure 6 – The EU objectives for the organic sector 

20 

Legal framework objectives

Strategic framework objectives

Environmental specific objective

•

improve the contribution of 
organic farming to sustainability

Market specific objectives

•

•

stimulate demand and ensure 
consumer trust

stimulate conversion and 
reinforce the entire value chain

Area-based objective

•

25 % of the EU’s agricultural land 
to be organically farmed by 2030

2021-2027 EU 
organic action 
plan

Farm to fork 
strategy and 
Biodiversity
strategy to 
2030

The Organic
Regulation

Environmental objectives 

•

•
•
•
•

•

•

•

protection of the environment and 
the climate

long-term soil fertility

high level of biodiversity

non-toxic environment

preservation of rare and native 
breeds in danger of extinction

development of the supply of plant 
genetic material adapted to the 
specific needs of organic farming

high level of biodiversity by using 
diverse plant genetic material

high animal welfare standards

Market objectives

•

•

short distribution channels and 
local production in the various areas 
of the EU

development of organic plant 
breeding activities in order to
contribute to favourable economic 
perspectives of the organic sector

Source: ECA based on Article 4 of Regulation (EU) 848/2018, and the 2021-2027 EU action plan for the 
development of organic production. 

Weaknesses in national policies hamper the development of the EU 
organic sector 

25 Since 2004, and with a view to increasing the effectiveness of public support for 
organic farming, the Commission has encouraged member states to develop national 
action plans for the organic sector11. Member states have no legal obligation to do so 
and the Commission does not systematically monitor the adoption of national action 
plans. 

11  Action 6 of the 1st EU organic action plan, and recommendations in the 2nd and 3rd EU 

organic action plans. 

 
 
 
 
21 

26 Specific national strategies or action plans show the commitment of the member 
states to developing the organic sector. A 2023 study tracked the preparation of such 
strategies or plans, which varied significantly from one member state to another – see 
Figure 7. By the end of 2023, all but three member states (Greece, Lithuania and 
Spain) had a national action plan in place. 

Figure 7 – The adoption of national action plans varies 

Number 
of action plans

Duration
(year start to year end)

1995

2000

2005

2010

2015

2020

2025

2030

Previous
Current or 
proposed

Denmark
Slovakia
Sweden
France
Austria
Germany
Netherlands
Latvia
Czechia
Spain**
Slovenia
Bulgaria*
Estonia
Belgium-Flanders
Ireland*
Luxembourg
Croatia
Poland
Belgium-Wallonia
Finland
Hungary
Italy
Portugal
Cyprus
Malta
Romania
Greece
Lithuania

Greece and Lithuania have never adopted an action plan for organic farming

* Draft action plan published for the current period.
** Draft action plan for the current period announced but not published.

Source: ECA based on information from audited member states, national actions plans and the study 
“Assessment of agricultural and aquaculture policy responses to the organic F2F targets”, Lampkin and 
al., 2024. 

 
 
 
22 

27 In 2023, the four member states we audited each had an action plan for the 
organic sector. According to experts and stakeholders consulted for the audit, the 
impact of these action plans on the organic sector is key where the sector is under-
developed. We found the following: 

o 

o 

In Poland, the impact of the 2014-2020 plan on developing the organic sector was 
weakened by the lack of targets, clear roles and responsibilities, and a financial 
allocation. The Polish authorities only defined targets and responsibilities for the 
plan in 2018. Poland more than doubled its consumption and sales of organic 
products in the 2014-2020 period. Despite this increase, it still had the 
seventh lowest levels of organic consumption and sales at the end of the period. 

Romania only adopted its first action plan in May 2023, although it had the eighth 
highest CAP spending for converting to or maintaining organic farming practices 
in the 2014-2022 period. In this action plan, we noted the same weaknesses in 
Romania as for Poland. 

28 To reach the 25 % target by 2030, the uptake of organic farming practices would 
need to double its current pace – see Figure 8. At the end of 2023, the European 
Environment Agency reported that “current policies in place and public support will 
most likely increase the share of organic farming but not sufficiently to meet the 
target”12. 

12  EEA Report 11/2023, “Monitoring report on progress towards the 8th EAP objectives 2023 

edition”, page 70, December 2023. 

 
 
 
23 

Figure 8 – The uptake of organic farming practices needs to double its 
pace to reach the 25 % target by 2030 

Estimate based on the previous 
annual growth rate

Estimate based on the annual growth 
rate needed to reach the 25 % target

30  %

25  %

20  %

15  %

10  %

5  %

0  %

5.9 %

Annual 
growth rate 
of 6 % 

9.9 %

Annual growth rate 
needs to almost 
double in 2021-2030 
from 6 % to 11 %

25 % 
target

16.7 %

Trendline, if the same 
annual growth rate is 
maintained at 6 %

2012

2018
Source: ECA calculations based on Eurostat and DG AGRI data. 

2016

2014

2024

2020

2022

2026

2028

2030

29 Actions taken by the member states are essential to be able to reach the 25 % 
organic farming target. For the 2023-2027 period, they had to establish a target for the 
CAP spending for organic farming. Some countries complemented the CAP target, 
which is to be achieved only through the CAP spending, with a national target, to be 
achieved also through the market for organic products and/or additional national 
financing. We found that the degree of ambition when setting these targets varies 
significantly – see Figure 9. 

 
 
24 

Figure 9 – National targets for organic farming vary significantly between 
member states 

Share of organic farming in 2022

CAP target 
for 2027

National target 
for 2027

National target 
for 2030

Share of land 
organically farmed

0 %

5 %

10 %

15 %

20 %

25 %

30 %

35 %

EU

Austria

Sweden

Portugal

Italy

Czechia

Latvia

Finland

Slovakia

Belgium - Wallonia

Denmark

Slovenia

France

Germany

Lithuania

Croatia

Hungary

Cyprus

Romania

Netherlands

Poland

Ireland

Bulgaria

Belgium - Flanders

Malta

Estonia

Greece

Spain

Luxembourg

Note: Luxembourg has a national target of 20 % of organic farming by 2025. Spain mentioned that the 
current trend would allow to reach 20 % by 2030, without setting this as a national target. Portugal set a 
national target of 12 % of organic farming by 2027 in 2017; this target was not updated. For Austria, we 
used 2020 data for the share of organic farming. 

Source: ECA based on CAP strategic plans, national action plans of member states, and Eurostat 2022 
organic farming statistics (extracted on 25 June 2024). 

 
 
 
25 

30 As for the national action plans, we found that the degree of maturity already 
achieved by the organic sector is a key factor when setting the national ambition for 
organic farming in the audited member states. Additional national financing also plays 
an important role – see in Box 1. 

Box 1 

Targets for organic farming vary in the audited member states 

For 2027, Italy and Austria set a lower target in their CAP strategic plans (11.9 % 
and 23.7 % respectively), compared to their national targets (25 % and 30 % 
respectively). It is planned that the additional increase should come from the 
already well-developed market for organic products in Austria, and from the 
rapidly growing market in Italy, as well as with additional national financing. 

Romania and Poland set a low CAP target (3.5 % and 4.5 % respectively), despite a 
high allocation of EU funds for organic farming. In Romania, we found that the CAP 
target for organic farming had been already achieved in 2021. 

31 In addition to increasing the organic area, member states can further support the 
development of the organic sector by establishing other national targets. We found 
such examples in 16 member states. For example, several member states opted for 
targets on organic production (eight member states), on organic consumption through 
public catering (10 member states) and on the processing of organic products (four 
member states). Of the four member states audited, only Austria had an additional 
target: to have 55 % organic food in public canteens by 2030. 

Member states only partially addressed the specific needs of their 
organic sector when programming CAP support 

32 In the four audited member states, the CAP was the main source of funding for 
national organic action plans. In the 2014-2022 period, member states mainly 
programmed their CAP spending through their national or regional rural development 
programmes (RDP). The RDPs: 

o 

o 

identified the specific needs of member states’ agricultural sectors; 

laid out strategies with objectives and targets, in line with EU priorities for rural 
development; and 

o 

selected support measures to achieve those targets and objectives. 

 
 
26 

33 We found that the four audited member states integrated to a limited extent in 
their RDPs the specific needs of their organic sector, with only: 

o 

o 

Poland identifying the specific need to develop organic farming as a sustainable 
form of agriculture; and 

Italy (Sicily) establishing an objective to promote the integration of organic 
production in the supply chain by improving organic farmers’ access to the 
market, strengthening their position in the value chain, and fostering innovation 
in the organic sector. 

All four member states used organic farming support as an instrument to tackle more 
general needs linked to preserving water resources, biodiversity, soil, or reducing 
greenhouse gas emissions, in line with EU priorities for rural development. 

34 Member states had the option to include sub-thematic programmes in their RDPs 
to address specific needs in areas of particular importance, or in agricultural sectors 
with a strong impact on the development of rural areas. We found that none of the 
27 member states had included a sub-thematic programme in their RDPs for organic 
farming or the organic sector. 

35 The 2023-2027 CAP gave member states three funding options to programme 
CAP support for organic farming – see Figure 10. We found no significant change in the 
way the four audited member states programmed support for organic farming for the 
2023-2027 period. Italy also integrated support for the uptake of organic farming 
practices in specific sectors (e.g., olive oil, fruit and vegetables, and potatoes). 
However, it was too early for us to assess the impact of this additional financing option 
on developing organic farming for these crops. 

 
 
Figure 10 – Member states had three funding options to support organic 
farming in the 2023-2027 CAP 

27 

Source: ECA based on the Organic farming in the EU – a decade of growth, January 2023. 

 
 
 
28 

Area increased, but it is still a challenge to integrate the 
objectives of organic farming in the CAP 

36 We examined whether CAP support for organic farming had been used effectively 
by the member states13 to support both the environmental and the market objectives 
of organic farming14. In the audited member states, we expected to find that: 

o 

o 

CAP funds supported the environmental objective of organic farming; 

CAP funds contributed to the market objective of organic farming; 

o  member states used CAP funds to further develop the organic sector. 

CAP support helped increase the organic area, but environmental 
benefits were not always guaranteed 

37 In the 2014-2022 period, the CAP supported organic farming through a specific 
measure in the rural development policy15 (referred to in this report as “CAP support 
for organic farming”). Compared with the 2007-2013 period, CAP support for organic 
farming was separated from other agri-environment commitments to emphasise its 
growing importance. 

38 Support under this measure was granted per hectare of eligible agricultural land 
for multi-annual commitments to convert to or maintain organic farming practices, as 
defined in the Organic Regulation. All member states except the Netherlands included 
CAP support for organic farming in their RDPs, with Germany, Italy, France, Greece, 
and Spain allocating 62 % of the total EAFRD budget to it – see Figure 11. 

13  Chapter 7 of Regulation (EU, Euratom) 2018/1046. 

14  Recitals 3 and 4 of Regulation (EU) 2018/848. 

15  Article 29 of Regulation (EU) No 1305/2013. 

 
 
 
29 

Figure 11 – Five member states account for 62 % of CAP support for 
organic farming in 2014-2022 

Budget allocated from the EAFRD in 
the period 2014-2022
Budget spent until 31.12.2023
billion euros

Increase in the 
organic area between 
2014-2021

Share of organic area 
receiving CAP support 
in 2021

%

%

0

0.5

1

1.5

2

2.5

0 %

100 % 200 % 300 % 0 %

100 %

Germany

Italy

France

Greece

Spain

Austria

Poland

Romania

Czechia

Sweden

Portugal

Denmark

Finland

Lithuania

Hungary

Croatia

Latvia

Bulgaria

Slovakia

Estonia

Belgium

Ireland

Slovenia

Cyprus

Luxembourg

Malta

Netherlands*

* No CAP support for organic farming programmed in the 2014-2022 RDP

Cyprus

Luxembourg

Malta

0

5

10

15

million euros

Note: The EAFRD budget includes the additional financial allocation from the EU Recovery Instrument 
(EURI), provided to member states for the recovery from COVID-19 for the 2021-2022 period.  

Source: ECA based on the financing plans in the RDPs as of 31 December 2023. 

 
 
 
30 

39 In 2021, 69 % of the almost 16 million hectares of organically farmed land in the 
EU received CAP support for organic farming16. The share of the supported area 
increased from 3.2 % in 2014 to 6.9 % in 202117. The CAP mainly finances organic 
farming to promote sustainable agriculture and to integrate environmental protection 
requirements into the policy18. The environmental benefits of this measure come from 
the rules set out in the Organic Regulation (see Figure 1). 

40 One of the essential organic farming practices is crop rotation, which contributes 
to soil fertility and health, and to the control of pests and diseases. Through the 
Organic Regulation, it is mandatory for organic farmers to implement multiannual crop 
rotation, and include legumes and other green manure crops in the rotation plan19. 
Since crop rotation is not defined in the Regulation, member states can establish 
additional national provisions on how this practice should be implemented. Of the four 
member states audited, only Italy had established such a definition. 

41 Nine out of the twenty-six farmers we visited in the four member states had been 
cultivating the same crop on the same parcel over several subsequent years, or had 
not been using legumes or other green manure crops. The lack of an adequate crop 
rotation in some cases led to the increased use of external inputs, such as commercial 
organic fertilisers and pesticides, which goes against the principle of restricting the use 
of such inputs in organic farming. 

42 In line with the organic livestock rules, farmers must comply with high animal 
welfare standards. These standards include the prevention of any animal suffering. If 
needed, member states can grant authorisations to farmers allowing them to deviate 
from certain animal welfare rules, provided the exemptions are kept to a minimum 
and, where appropriate, are limited in time20. In the audited period, we found that 
organic farmers in Austria, Poland, and Italy benefited from general authorisations on 
animal welfare at national level for many consecutive years – see Box 2. Farmers 
making use of the authorisations were eligible for CAP support for organic farming. 

16  Calculated by ECA based on Eurostat data for 2021, and DG AGRI Data Portal. 

17  Calculated by ECA based on DG AGRI Data Portal. 

18  Recital 4 of Regulation (EU) 2018/848. 

19  Article 12(1) in Regulation (EC) 834/2007 and Annex II (1.9 and 1.10) of Regulation (EU) 

2018/848. 

20  Article 22 of Regulation (EC) 834/2007. 

 
 
 
31 

Box 2 

CAP support for organic farming was granted without respecting 
animal welfare rules 

Starting in 2015, organic livestock farmers in Austria benefited from general 
authorisations for certain animal management practices. This meant that farmers 
were allowed to remove animals’ horns, tails, or teeth, to not provide animals 
with access to grazing in open areas, and to tether cattle on small farms. Following 
audits in 2017 and 2019, the Commission recovered €16.4 million of undue 
CAP payments to organic livestock farmers for not respecting animal welfare rules. 
Austria removed these general authorisations in 2021. 

We found that Italy (since 2009) and Poland (since 2015) have been granting a 
similar general authorisation for tethering animals on small farms. Poland 
withdrew this authorisation in 2022, while Italy continues to apply it. 

The Commission is responsible for monitoring how member states implement 
authorisations in organic farming. However, the Organic Regulation does not 
require member states to inform the Commission about general authorisations for 
tethering animals on small farms or for animal mutilations. The Commission was 
therefore unaware of these cases. 

43 The Organic Regulation establishes a set of voluntary principles for organic 
farming, such as the preservation of landscape elements, the responsible use of 
natural resources, and the limited use of external inputs. Member states can reinforce 
the positive impact on the environment by integrating these principles into CAP 
support for organic farming (see Figure 1). In the four audited member states, we 
found that the measure rarely integrated organic farming principles. However, we 
noted two examples of good practices in Austria and Poland – see Box 3. 

Box 3 

Examples of additional environmental provisions included in the CAP 
support for organic farming 

Austria used part of the budget for the measure to pay the organic farmers who 
voluntarily preserved permanent grassland and landscape elements on their 
farms. 

Poland made the preservation of grassland and landscape elements a condition 
for all organic farmers to receive financial support. 

 
 
32 

Member states did not always ensure that CAP support for organic 
farming leads to organic production 

44 According to the Organic Regulation, the aim of organic farming should be to 
produce a wide variety of foods that respond to consumers’ demand for goods 
produced in a way that does not harm the environment, human health, plant health, 
or animal health and welfare21. In the 2014-2022 period, CAP support for organic 
farming was meant to compensate farmers for the additional costs and income lost 
due to switching from conventional to organic farming. Organic farmers were not 
required to produce any organic products to receive this support. 

45 To avoid the possibility of supporting non-productive areas, Austria, Poland and 
Italy asked famers to produce an output from the parcels that received support, e.g. to 
harvest their crops, or use their grass to feed animals. In Poland, this requirement 
translated into an increase in organic production – see Box 4. Since 2023, farmers in 
Italy (Sicily) who sell their production as organic are priority recipients of EU support. 

Box 4 

Change in conditions to receive CAP support for organic farming 
helped increase organic production in Poland 

In its 2014-2022 RDP, Poland introduced a requirement for farmers benefiting 
from CAP support to produce agricultural goods on the committed parcels (e.g., 
either use the grass to feed animals or sell it, harvest orchard fruits). This key 
change in the eligibility conditions led to a drop in the organic area between 2015 
and 2019. At the same time, organic production continued to increase. Since 2021, 
Poland has experienced significant growth in terms of both organic area and 
organic production. 

46 In 2020, almost 60 % of the EU’s organic area was covered by permanent 
grassland and fodder. However, organic livestock remains a niche market in the EU. 
In 2020, organic cattle only accounted for 6 % of all cattle in the EU, while organic 
poultry and pigs represented 3.6 % and 1 % of the total population respectively22. 
Since CAP support for organic farming is area-based, the market remains the main 
incentive for livestock farmers to convert their animals to organic farming. 

21  Recital 1 and Article 3 of Regulation (EC) 834/2007. 

22  Commission, Agricultural market brief “Organic farming in the EU – a decade of growth”, 

p. 6, January 2023. 

 
 
 
33 

47 In Romania, we found that while the area covered by organic grassland and 
fodder more than doubled in the 2014-2021 period, the number of organic grazing 
animals dropped by 75 %. The organic farming measure supported almost 100 % of the 
organic grassland in Romania with no incentive for organic livestock. In contrast, Italy 
and Austria did include such incentives in this measure – see Figure 12. 

Figure 12 – Incentives for organic livestock in the CAP support for organic 
farming 

Source: ECA based on RDPs. 

 
 
 
34 

48 Organic farmers have the obligation to use organic seeds when planting their 
crops 23. When organic seeds are not available on the market, farmers can ask for a 
derogation to use non-organic seeds24. An EU-funded study25 from 2021 estimated 
that EU organic farmers purchase between 23 % (for oats) and 75 % (for carrots) of 
their seeds as non-organic. 

49 The demand for organic seeds can provide an additional economic incentive for 
organic farmers to produce them. However, in all four audited member states, we 
found that it was common practice to obtain derogations for using non-organic seeds. 
In the audited period in the four audited member states, the number of derogations 
generally increased proportionally to the organically farmed land. 

50 While it has been mandatory for the member states to establish a database 
listing the varieties of organic seeds available on their territory since 200926, seed 
suppliers are not required to provide this data. In Romania and Italy, we found that 
these databases were out of date, static, or contained very few entries. 

51 Since 2009, member states have annually informed the Commission about the 
use of conventional seeds in organic farming, including the crop varieties and the 
quantities needed by farmers. According to the Commission, this information was used 
to better programme EU research funds to improve organic seed availability. The same 
2021 EU-funded study 27 (see paragraph 48) also surveyed 839 farmers across 
17 member states and found that the availability of locally adapted organic seeds 
remained an issue for 60 % of farmers. 

23  Article 12(1i) of Regulation (EC) 834/2007 and Annex II (1.8.1) of Regulation (EU) 2018/848. 

24  Article 22 of Regulation (EC) 834/2007 and Annex II (1.8.5.1) of Regulation (EU) 2018/848. 

25  LIVESEED project, “The state of organic seeds in Europe”, p. 23, 2021. 

26  Article 48 of Regulation (EC) 889/2008. 

27  LIVESEED project, “The state of organic seeds in Europe”, p. 23, 2021. 

 
 
 
35 

Member states did not target CAP funding sufficiently well to further 
develop the organic sector 

52 A well-developed market for organic products can reward organic farmers 
through an additional price premium. The Commission’s 2021 evaluation of the CAP’s 
impact on natural resources highlighted that farmers mainly convert to organic 
farming due to the economic perspectives offered by the market, rather than 
environmental considerations. 

53 Since 2014, the Commission has encouraged member states to make use of other 
CAP support measures28 in their RDPs, to ensure the overall development of the 
organic sector, and thus increase the impact of the EU support for organic farming. 
However, it provided little guidance on how to do so. A CAP thematic group was set up 
only in 2022 to exchange best practices between member states on how to use CAP 
funds to strengthen the position of organic farmers in the value chain29. 

54 In their 2014-2022 RDPs, member states were able to support the organic sector 
by using several EAFRD measures – see Figure 13. We found that all four audited 
member states established provisions for either organic farmers or for the organic 
sector through CAP measures other than support for organic farming. However, they 
could not say whether these provisions gave an advantage to organic operators in 
accessing financial support. Audited member states did not monitor or assess the 
impact of the funding provided to the organic sector from these measures. 

28  Commission guidance to member states for CAP support for organic farming. 

29  European CAP Network, Strengthening the position of farmers in the organic food supply 

chain. 

 
 
 
Figure 13 – Other rural development measures were available to support 
the organic sector 

36 

Transfer knowledge 
to farmers 
(e.g. training and 
demonstrations) 

Cooperate in the 
value chain 
(e.g. develop short 
supply chains)

Advise farmers

CAP support for 
organic farming

Set up producer 
groups and 
organisations

Register products in 
quality schemes 
(e.g., organic farming)

Invest in farms, develop 
and promote products, 
and set up processing 
facilities

Source: ECA based on Commission information. 

55 All four member states expressed the need to help organic farmers build 
knowledge, through specific training, advisory services or demonstration farms. Both 
Romania and Poland planned specific calls targeting organic farmers for these 
measures in their RDPs. However, no organic farmers in Romania benefited from such 
specific training or advisory services because no trainers or advisors replied to the 
published call for proposals. Poland only started using the two measures in 2022. 

 
 
 
37 

56 A 2014 evaluation report of the EU legislation on organic farming stressed that 
there is “a clear potential for socio-economic benefits if organic development can be 
targeted at small farms in disadvantaged rural areas”. However, small farmers face 
barriers in converting to organic, such as the financial burden of certification and 
inspection costs, and the administrative burden in keeping detailed records as required 
by the Organic Regulation30. The average size of organic farms in the EU (41 ha) is 
2.5 times larger than the average size of conventional farms (16 ha)31. 

57 To help small farmers overcome these barriers, Austria, Italy and Poland opted to 
pay the inspection and certification costs for the first 5 years of organic farming 
through support for quality schemes. In Romania, these costs were considered as 
transaction costs and included in the CAP support for organic farming. To encourage 
smaller farms to convert to organic, Poland also decreased the CAP support for organic 
farming for farms above 50 hectares by up to 60 %. However, reducing payments for 
larger farms did not lead to the expected impact on smaller farms. 

58 Since 2022, the Organic Regulation32 has allowed small farmers to opt for group 
certification to reduce their costs. Despite the large number of small farmers 
particularly in Poland and Romania, none of the four audited member states used this 
possibility. Farmers do not use the group certification option, mainly due to its unclear 
legal status and definitions33. 

59 Member states could further help organic farmers by providing them with CAP 
financial support to modernise their farms, build storage facilities, or buy machinery 
adapted to organic farming. None of the audited member states launched specific calls 
for organic operators in the measure for investments. However, they all gave organic 
farmers preferential access to funding, with varied results, as shown in Box 5. Audited 
member states also gave additional points to those projects that promoted 
cooperation between organic farmers, developed the processing of organic products, 
or set up short organic supply chains. 

30  Commission, Impact assessment for the Proposal for a Regulation on organic production 

and labelling organic products, SWD(2014) 65, 2014. 

31  Commission, Agricultural Market Brief “Organic Farming in the EU”, 2023. 

32  Article 36 of Regulation (EU) 2018/848. 

33  FAQ on the Organic Regulation. 

 
 
 
38 

Box 5 

Preferential access for organic farmers to investment support gave 
varied results 

Austria and Romania gave organic farmers an increased co-financing rate, of 5 % 
and 20 % respectively, to invest in their farms. Authorities did not know what the 
impact was on organic farmers. In Romania, other categories of farmer benefited 
from the increased co-financing rate, thus diluting the incentive to further drive 
conversion to organic farming. 

In Poland, support to modernise farms excluded any investments in the field of 
poultry breeding, unless the production was already organic, or would be 
converted to organic. Between 2014 and 2022, the organic poultry population 
more than tripled. 

Italy (Sicily) gave organic farmers additional points when selecting projects for EU 
support to invest in their farms. However, due to the availability of funds, all 
eligible applications received funding, resulting in no advantage to organic 
farmers. 

Data constraints limit sound policy making for the organic 
sector 

60 The Commission and the member states should establish an appropriate and 
reliable monitoring and evaluation system for the CAP spending for organic farming34, 
and ensure that adequate data on the organic sector is available to support the policy-
making process35. We expected to find that: 

o 

o 

o 

the monitoring and evaluation framework put in place had provided appropriate 
information on the results of the CAP support for organic farming and its impact 
on achieving the CAP objectives; 

the Commission had used other available data sources to complement the 
monitoring and evaluation framework; and 

the Commission had ensured the availability and relevance of data on the organic 
sector to support the policy making process. 

34  Commission Implementing Regulations (EU) 834/2014 and 808/2014. 

35  Recital 36 of the Regulation (EC) No 834/2007. 

 
 
 
39 

The impact of the CAP support for organic farming cannot be assessed 

61 The aim of providing financial support for organic farming was to contribute36 to 
the general CAP objective of sustainably managing the EU’s natural resources and the 
climate, by: 

o 

o 

providing environmental benefits; and 

indirectly contributing to increasing farmers’ income, meeting consumer 
expectations, and maintaining agricultural diversity. 

62 To measure whether support for organic farming achieves these objectives, the 
Commission used the CAP’s common monitoring and evaluation framework37 (CMEF). 
The organic farming indicators in the CMEF are shown in Figure 14. 

Figure 14 – Indicators for organic farming under the 2014-2022 CAP 

Output

Result

Context

Total public expenditure

Number of farms/farmers 
receiving CAP support for 
organic farming 

Total agricultural area 
receiving CAP support for 
organic farming

No result indicator

Total agricultural area 
under organic farming 

Source: ECA based on Implementing Regulation (EU) No 834/2014 and Implementing Regulation (EU) 
No 808/2014. 

63 The CMEF did not include a result indicator for support for organic farming. The 
three output indicators provide information on how the financial support was used 
(i.e. how much money was spent, for how many organic farmers, and for how many 
hectares), but not on the impact of the support or its contribution to the CAP 
objectives. 

36  DG Agriculture and rural development, “Technical handbook on the monitoring and 
evaluation framework of the common agricultural policy 2014-2020", 2017, p. 14. 

37  Commission Implementing Regulations (EU) No 834/2014 and No 808/2014. 

 
 
 
 
40 

64 Member states can develop additional indicators to measure the effects of their 
rural development programmes. We found that none of these additional indicators 
was related to organic farming. However, the two Italian regions we visited for this 
audit did collect additional information on organic farming to assess its impact on the 
environment and on the climate – see Box 6. 

Box 6 

Italian regions collect information to monitor the impact of CAP 
support for organic farming on the environment and on the climate 

Campania put in place a specific monitoring framework for the CAP support for 
organic farming, reporting annually on carbon and nitrates in the soil, greenhouse 
gas emissions, and the risk of soil erosion. 

In Sicily, organic farmers who are supported by this measure must submit: 

o 

a technical report certified by an agronomist, with detailed information about 
the farm, including the presence of landscape elements, water resources, and 
protected areas; 

 
 
 
41 

o 

a humus analysis that provides information on the health and fertility of the 
soil, which is to be repeated at the end of the commitment to assess the 
effectiveness of organic farming practices for the soil. 

However, we found that the regional authority did not use the information 
collected. 

65 For the 2023-2027 period, the CMEF was replaced by the performance 
monitoring and evaluation framework (PMEF). The output indicators were maintained 
and the Commission added a result indicator: the share of organic area receiving CAP 
financial support for organic farming. As noted in our Opinion 7/2018, this result 
indicator in fact reflects output, without measuring the effects of the support for 
organic farming. As an improvement, the PMEF tracks the CAP funds paid to organic 
farmers 38. 

66 To assess the contribution of rural development measures in terms of achieving 
CAP objectives, the member states and the Commission also carry out evaluations. 
In 2019, member states conducted a mid-term evaluation of their RDPs. None of the 
four audited member states included information on the CAP support for organic 
farming contribution to the objectives set in their RDPs. In 2021, the Commission also 
carried-out two evaluations of the CAP’s impact on climate change and natural 
resources. Both evaluations stated that the direct contribution of specific measures to 
achieving CAP objectives could not be evaluated. 

Existing EU tools are not fit for analysing the impact of organic farming 

67 To analyse the impact of EU financial support for organic farming on achieving 
the objectives set at EU level, the Commission mainly uses economic data on organic 
farms from the Farm Accountancy Data Network (FADN)39. The FADN provides data on 
income by farm and worker, labour intensity, and the cost of fertilisers, pesticides, and 
veterinary products. 

38  Annex IV, point 4(i) of Commission Implementing Regulation (EU) 2022/1475. 

39  JRC, “Analysing the Feasibility of Counterfactual Methods for Estimating Environmental 

Effects of the CAP”, 2023. 

 
 
 
42 

68 Of the 80 000 farms included in the database, 10 % are organic. These farms are 
unevenly distributed across member states and are not representative40. This 
constitutes a limitation in using the FADN to analyse the impact of organic farming. In 
November 2023, the FADN was replaced by the Farm Sustainability Data Network 
(FSDN)41, which is not yet operational. 

69 The 2021 EU organic action plan includes an action to continuously collect data 
about the environmental, economic and social benefits of organic farming, starting 
in 2022. The FSDN will collect environmental and social data from EU farms, in addition 
to the economic data already collected. However, the Commission has not yet 
addressed the limitation regarding organic farms, either in the FADN or in the FSDN. 

70 According to the Commission, environmental data in the FSDN could be 
complemented by using the soil module of the Land Use and Cover Area frame Survey 
(LUCAS Soil). This module provides information on soil degradation, soil erosion, soil 
compaction, soil pollution, changes in the organic carbon levels in soil, and 
biodiversity. However, the tool does not identify which samples come from organically 
farmed soil. 

71 This information is available in the member states, in the information systems 
used to locate agricultural parcels and process CAP payments to farmers. In 2023, only 
half of the member states were providing the Commission with partial access to this 
information, mainly for reasons of confidentiality. 

Fewer statistical variables collected on the organic sector 

72 Statistical data on the organic sector is essential to assess the EU’s policy on 
organic farming, and to monitor the progress of EU organic action plans 42. Since 2008, 
all member states have had43 to send annually detailed data on the organically farmed 
land to the Commission, for the organic crop and animal production, the organic 
livestock, and the number of organic operators. 

40  Commission, Agricultural market brief “Organic farming in the EU – a decade of growth”, 

January 2023, page 9. 

41  Regulation (EU) 2023/2674. 

42  Recital (20) of Regulation (EU) 2022/2379. 

43  Article 36 of Regulation (EC) No 834/2007, and Article 93 of Commission Regulation (EC) 

No 889/2008. 

 
 
 
43 

73 In 2022, when the current Organic Regulation entered into force, this obligation 
was removed, and collecting statistical data for the organic sector became voluntary 
for the member states. So far, only eight member states44 formally agreed to continue 
sending data on organic farming to the Commission45. As a result, due to missing data 
from the member states, many EU aggregates are no longer calculated for 2021 
and 2022, including those for organically farmed land. 

74 From 2026, it will once again become compulsory for all member states to send 
organic farming statistics. Data will be collected, together with other agricultural 
statistics, through the Regulation on statistics on agricultural input and output, known 
as the SAIO Regulation. According to the Commission, this will provide better quality 
assurance, since all member states will need to systematically ensure coherence and 
consistency between organic farming data and other agricultural data. 

75 As an improvement, the SAIO Regulation will collect new data on how much 
organically farmed land is treated with pesticides and the quantity used. Compared to 
the Organic Regulation, the SAIO Regulation will require fewer statistical variables on 
organic farming – see Figure 15. As a result, the Commission already reduced the 
amount of data collected for the organic sector in 2022. 

44  Spain, Finland, Italy, Lithuania, Latvia, Malta, Sweden, and Slovakia. 

45  ESS agreement on organic statistics, 12 February 2020. 

 
 
 
Figure 15 – Since 2022, less data has been collected on organic farming 
and production 

44 

= number of statistical variables collected

Data collected

2009-2021 
through 
the Organic 
Regulation

2022-2025 
through 
a voluntary 
agreement

2026 onwards 
through 
the SAIO 
Regulation

Organic operators 

Crop area under 
conversion to 
organic farming

Crop area fully 
converted to 
organic farming

Organic crop 
production

Organic livestock

Organic animal 
production

Data no longer 
collected through 
the SAIO 
Regulation from 
2026 onwards

for example, organic 
producers, processors 
(by industry), 
importers and 
exporters

all but the total 
agricultural area, 
arable land, 
permanent crops and 
permanent grassland

for example, data for 
crops under 
greenhouses and 
fallow land

for example, data for 
wheat and spelt, dry 
and protein crops, 
root crops, oilseed, 
fibre crops, tobacco 
and hops

for example, data on 
horses, rabbit, poultry 
other than laying 
hens, and beehives

for example, data for 
poultry other than 
chicken, buffalo milk 
and honey

Source: ECA based on Eurostat questionnaires and the implementing acts of the SAIO Regulation. 

 
 
 
45 

76 It has been a long-standing need for the EU organic sector46 to improve market 
information for organic food products. But collecting more data entails an extra cost 
for both member states and the Commission. In 2021, the Commission started 
publishing monthly data on the prices of organic food products to complement the 
statistics already collected47. Although this is a step in the right direction, the data 
suffers from important quality issues (i.e., it is not comparable from one member state 
to another, prices are collected at different stages in the food chain, and significant 
amounts of data are missing). 

77 Member states can also collect additional national market data for organic 
products. During our audit visits to the member states, we found that in their organic 
action plans, Italy and Romania highlighted the need to improve market transparency 
through having better data on national consumption and the movements of organic 
goods within the EU. However, they had not yet taken action on this point. In Austria, 
the authorities purchase detailed domestic market data from private data providers. In 
Denmark, detailed market data is collected through the national statistical office – see 
Box 7. 

Box 7 

Denmark collects detailed market data for the organic sector 

Denmark collects and publishes annual market data for the organic sector through 
its national statistical office. Danish retailers have a legal obligation to provide 
detailed information on: 

o 

o 

the sale of organic products on the domestic market and to all countries 
outside Denmark, and the sales channels used; 

purchases of organic products from other member states, or from outside 
the EU; and 

o 

the turnover and market share by group of products. 

46  EU organic action plans. 

47  Since 2021, member states have had to communicate the monthly prices for a set of 

organic products to the Commission (Regulation EU 2019/1746 modifying 
Regulation 2017/1185 – Annex II). 

 
 
 
 
 
46 

Conclusions and recommendations 

78 Overall, we concluded that there were gaps in the EU and national policies for the 
organic sector. CAP funds were used to increase the agricultural area for organic 
farming, without sufficiently taking into account the environmental and market 
objectives set in the EU policy for organic farming. Lastly, the impact of the policy 
could not be assessed due to data constraints. 

79 We found that the EU policy for the organic sector is weakened by gaps in the 
strategic framework. The Commission uses action plans to steer the sector’s 
development. Although the 2021-2027 action plan is an improvement on the previous 
one, its three main objectives still do not include quantifiable targets, nor any means 
to measure progress. The EU target of having 25 % of organically farmed agricultural 
land by 2030 is not complemented by targets that address other elements of the 
sector. There is no EU strategy or any targets for the organic sector beyond 2030 
(paragraphs 19-24). 

80 Action at national level is essential to support EU policy. We found that member 
states developed domestic policies for the organic sector at different speeds and with 
varying levels of quality. They only partially addressed the specific needs of their 
organic sector when programming CAP funds (paragraphs 25-35). 

Recommendation 1 – Strengthen the EU strategic framework 
for the organic sector and improve the link with the CAP 
support 

The Commission should: 

(a) 

improve the EU strategic approach for the organic sector, by 

(i)  defining a long-term vision for the sector going beyond 2030; 

(ii)  setting measurable goals and baseline indicators to assess progress achieved; 

(iii)  considering additional targets to complement the 25 % area-based target for 
organic farming, to ensure the overall development of the sector (e.g. to 
encourage organic production and consumption). 

 
 
47 

(b) 

in the post-2027 CAP, encourage member states to better link the use of CAP 
support to the needs they identified for the organic sector. 

Target implementation date: (a) by the end of 2026 and (b) by the end of 2027. 

81 We found that member states had not ensured a consistent implementation of 
the organic rules, and rarely included any organic principles beyond the legal 
requirements in the CAP support for organic farming (paragraphs 37-43). The 
widespread use of derogations for non-organic seeds does not encourage farmers to 
produce organic seeds and develop this market (paragraphs 44-51). Other than 
supporting the uptake of organic farming, member states did not target CAP funding 
sufficiently well to strengthen the farmers’ position in the value chain and further 
develop the organic sector (paragraphs 52-59). 

Recommendation 2 – Better integrate the environmental and 
market objectives of organic farming in the CAP 

The Commission should: 

(a)  provide guidance to member states to apply the rules defined in the Organic 

Regulation consistently, and better integrate the organic principles in the CAP 
support for organic farming; 

(b)  assess the contribution of CAP funds to the economic sustainability of organic 
farming to better target the post-2027 CAP support at the organic sector; 

(c)  analyse the use of all organic farming authorisations and derogations and, if 

appropriate, take remedial actions. 

Target implementation date: by the end of 2026. 

82 The CAP mainly supports organic farming for the expected environmental and 
climate benefits. However, the monitoring and evaluation framework put in place by 
the Commission and the member states only allows EU spending to be monitored, but 
not its impact to be assessed (paragraphs 61-66). The Commission could assess the 
impact of CAP support though other existing EU tools, but they do not contain relevant 
and representative information for organic farming (paragraphs 68-71). The policy-
making process continues to be affected by the limited availability of data on the 
organic sector, including data on the market for organic products (paragraphs 72-77). 

 
 
48 

Recommendation 3 – Ensure the availability of relevant data to 
assess the development of organic farming 

The Commission should: 

(a)  based on data already collected, work with member states to evaluate the 
contribution made by CAP support for organic farming to achieve the CAP’s 
objectives; 

(b)  collect relevant and representative information on organic farming in the FSDN to 

assess the impact of CAP support; 

(c)  analyse the need to collect more granular data on the organic sector (e.g. organic 

operators, area under conversion) to support policy decisions. 

Target implementation date: (a), (b) by the end of 2027 and (c) by the end of 2028. 

This report was adopted by Chamber I, headed by Ms Joëlle Elvinger, Member of the 
Court of Auditors, in Luxembourg at its meeting of 10 July 2024. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
 
49 

Annex – Consumption of organic 
products in member states 

Denmark

Austria

Luxembourg

365

274

259

Per capita consumption 
of organic products 
(€/person)

one line = one euro

10 euros

100 euros

Per capita gross 
domestic product 
(purchasing power 
standard/person)

0

20

40

60

80

100

euros

0

20

40

60

80

100 thousand

Sweden

Germany

France

Belgium

Netherlands

248

181

176

84

81

Finland

Estonia

73

72

Italy

62

Spain

Ireland

55

47

Slovenia

Croatia

Czech Republic

Lithuania

Poland

27

24

22

18

8

Latvia

Greece

Bulgaria

Hungary

Romania

6

6

6

3

2

Note: There is no data available for the consumption of organic products in Cyprus, Malta, Portugal, or 
Slovakia. 
Source: ECA based on 2022 data from FIBL data on organic retail sales, and from Eurostat data on gross 
domestic product (last extracted on 20 April 2024). 

 
 
 
50 

Abbreviations 

CAP: Common agricultural policy 

CMEF: Common monitoring and evaluation framework 

EAFRD: European Agricultural Fund for Rural Development 

FADN: Farm Accountancy Data Network 

FSDN: Farm Sustainability Data Network 

LUCAS: Land Use and Coverage Area frame Survey 

PMEF: Performance monitoring and evaluation framework 

RDP: Rural development programme 

 
 
 
 
51 

Glossary 

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

European Green Deal: EU growth strategy adopted in 2019, aiming to make the EU 
climate-neutral by 2050. 

Horizon Europe: The EU’s research and innovation funding programme for the 
2021-2027 period. 

Horizon 2020: The EU’s research and innovation funding programme for the 
2014-2020 period. 

Organic supply chain: All activities performed undertaken to deliver organic products 
to an end consumer, including in particular farming, processing, distribution and retail. 

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

Utilised agricultural area: Total area of farmland comprising arable land, permanent 
grassland, permanent crops and kitchen gardens. 

 
 
 
 
 
52 

Replies of the Commission 

https://www.eca.europa.eu/en/publications/sr-2024-19 

Timeline 

https://www.eca.europa.eu/en/publications/sr-2024-19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
53 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies and 
programmes, or of management-related topics from specific budgetary areas. The ECA 
selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming 
developments and political and public interest. 

This performance audit was carried out by Audit Chamber I – Sustainable use of 
natural resources, headed by ECA Member Joëlle Elvinger. The audit was led by ECA 
Member Keit Pentus-Rosimannus, supported by Annikky Lamp, Head of Private Office 
and Daria Bochnar, Private Office Attaché; Ramona Bortnowschi, Principal Manager; 
Mihaela Vacarasu, Head of Task; Grzegorz Grajdura, Vincenza Ferrucci, Irina Flat, 
Anca-Florinela Cristescu, and Mateusz Minich, Auditors. Laura McMillan provided 
linguistic support. Alexandra Mazilu provided graphical support. 

From left to right: Irina Flat, Vincenza Ferrucci, Ramona Bortnowschi, Annikky Lamp, 
Keit Pentus-Rosimannus, Grzegorz Grajdura, Mihaela Văcărașu, Daria Bochnar. 

 
 
 
 
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Organic farming is an agricultural method to produce food using 
natural substances and processes. The Commission set the target 
of having 25 % of the EU’s agricultural land organically farmed 
by 2030 – a significant jump from 10.5 % in 2022. We found that 
the EU strategy for organic farming lacked important elements 
such as quantifiable objectives and how to measure progress. The 
EU funds for organic farming – over €12 billion in 2014-2022 – 
helped to increase the organic area, but the environmental and 
market objectives were not sufficiently taken into account. 
Moreover, due to data constraints, the policy’s impact could not 
be assessed. We have made recommendations to improve the 
strategy and effectiveness of the EU funds for the organic sector. 

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

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