COMMISSION STAFF WORKING DOCUMENT Simplification measures for farmers Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2021/2115 and (EU) 2021/2116 as regards good agricultural and environmental condition standards, schemes for climate, environment and animal welfare, amendments to CAP Strategic Plans, review of CAP Strategic Plans and exemptions from controls and penalties
Date: 2024-12-10
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: EAFRD, EAGF, EU strategy, adaptation to climate change, administrative formalities, aid to agriculture, common agricultural policy, farming sector, sanction (EU), sustainable agriculture, utilised agricultural area

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.12.2024  SWD(2024) 360 final  COMMISSION STAFF WORKING DOCUMENT Simplification measures for farmers Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2021/2115 and (EU) 2021/2116 as regards good agricultural and environmental condition standards, schemes for climate, environment and animal welfare, amendments to CAP Strategic Plans, review of CAP Strategic Plans and exemptions from controls and penalties {COM(2024) 139 final/2}  
 
 
CONTENTS 

1. INTRODUCTION ............................................................................................................... 3 

2. POLITICAL AND LEGAL CONTEXT ............................................................................ 3 

3. CONSULTATION STRATEGY AND EVIDENCE GATHERING ................................ 6 

3.1. Consultation of EU farming organisations, Member States, and the Committee on 

Agriculture and Rural Development of the European Parliament ............................. 6 

3.2. Consultations specific to individual measures ............................................................ 6 

3.3. Gathering further evidence.......................................................................................... 7 

4.  OPTIONS  CONSIDERED  AND  THE  CHOICE  OF  INSTRUMENTS  FOR  THE 
PROPOSED SOLUTION................................................................................................ 9 

4.1. Common agricultual policy (CAP) strategic plans: management, administration and 
checks ......................................................................................................................... 9 

4.2. CAP strategic plans: the green architecture .............................................................. 10 

4.3. Farm income and competitiveness ............................................................................. 11 

4.4. Other CAP instruments .............................................................................................. 11 

4.5. Legislation outside the CAP ...................................................................................... 11 
5. DESCRIPTION OF THE ACTIONS TAKEN ............................................................... 12 

5.1 CAP strategic plans: management, administration and controls ................................ 12 

5.2. CAP strategic plans: the green architecture .............................................................. 17 

5.3 Farm income and competitiveness ............................................................................. 20 

5.4 Other CAP instruments .............................................................................................. 20 

5.5 Elements outside the CAP ......................................................................................... 21 

6. MAIN IMPACTS OF THE SIMPLIFICATION MEASURES ..................................... 23 

6.1 Impacts on the administrative burden for beneficiaries and national administrations23 

6.2 Other economic impacts............................................................................................. 25 

6.3 Environmental impacts .............................................................................................. 27 

6.4 Social impacts ............................................................................................................ 32 

6.5 Impacts relating to the performance, monitoring and evaluation framework ............ 32 

7. CONCLUSIONS ................................................................................................................ 34 

ANNEXES .............................................................................................................................. 36 

Annex 1. Actions announced by the Commission on 22 February 2024 and their delivery
 .......................................................................................................................................... 36 
Annex 2. Overview of the received simplification suggestions ...................................... 39 
Annex 3. Impact analysis. Who is affected and how? ................................................... 129 
Annex 4. Modelling the impact of removing the GAEC 8 first requirement (share of non-
productive areas and elements in arable land) according to the IFM-CAP model. ....... 134 

1 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AECM 

Agri-environment-climate measure 

AGRIFISH Council 

Agriculture and Fisheries Council configuration 

AKIS 

AMS 

APR 

CAP 

CEADS 

CEJA 
COM AGRI 

CLLD 
COPA-COGECA 
CAP Plan 
CSP Regulation 
DG AGRI 
EAGF 
EAFRD 
ECVC 
EFA 

EFSA 

ESPG 

FADN 
GAEC 
GHG emissions 
GSA 
Horizontal 
Regulation  
IACS 
IFM-CAP 
IFOAM 
LPIS 

LUCAS survey 
MFF 
NDM 
PMEF 

PO 

PPP 

SCO 

Simplification 
package 

Simplification 
Regulation 
SMR 

Agricultural Knowledge and Innovation Systems 

Area monitoring system 

Annual performance report 

Common agricultural policy 

Common European agricultural data space 

European Council of Young Farmers 
Committee on Agriculture and Rural Development of the European Parliament 

Community-Led Local Development 
European farmers/European agri-cooperatives 
CAP Strategic Plan 
CAP Strategic Plan Regulation (Regulation (EU) 2021/2115) 
Directorate-General for Agriculture and Rural Development 
European Agricultural Guarantee Fund 
European Agricultural Fund for Rural Development 
European Coordination Via Campesina 
Ecological focus area 

European Food Safety Authority 

Environmentally sensitive permanent grassland 

Farm accountancy data network 
Good agricultural and environmental condition 
Greenhouse gas emissions 
Geo-spatial application 
Regulation on the financing, management and monitoring of the common 
agricultural policy (Regulation (EU) 2021/2116) 
Integrated administration and control system 
Individual farm model for Common Agricultural Policy analysis 
European umbrella organisation for organic food and farming 
Land parcel identification system 

Land use/cover area frame statistical survey 
Multiannual financial framework 
New delivery model 
Performance monitoring and evaluation framework 

Producer organisation 

Plant Protection Product 

Simplified cost option 
The package of measures put forward by the Commission on 22 February 2024, 
including the Commission legislative proposal of 15 March 2024 to amend the CSP 
Regulation and the Horizontal Regulation  
Regulation (EU) 2024/1468 amending the CSP Regulation and the Horizontal 
Regulation based on the Commission proposal of 15 March 2024 
Statutory management requirement 

2 

 
 
 
 
1.  INTRODUCTION 

On 22 February 2024 the Commission put forward a simplification package of measures to 
ease the administrative burden on farmers and help them tackle the challenges that had arisen 
since the reform of the common agricultural policy (CAP) for 2023-20271. The measures that 
were announced are presented in Annex 1.  

On 15 March 2024, the Commission proposed2 targeted changes to the underlying CAP basic 
legislation  (the  CAP  Strategic  Plan  Regulation  and  the  Horizontal  Regulation)3  to  deliver 
simplification  while  maintaining  the  overall  orientation  of  the  current  CAP  and  its  role  in 
supporting the transition of European agriculture to sustainable farming. Without changes in 
substance, the proposal was adopted by the co-legislators and then published on 24 May 20244 
(the Simplification Regulation). These measures are accompanied by changes to some of the 
detailed rules of the CAP set in the secondary legislation, and by other measures to reduce 
the administrative burden on farmers as part of the Commission’s wider policy to rationalise 
reporting obligations, launched in 20235. 

This document takes stock of progress in implementing the simplification package, which 
includes the Commission proposal of 15 March 2024. It outlines the key challenges, the process, 
the results of the consultations that fed into the package, and the different options considered. 
Following a presentation of the solutions that were found, it provides a qualitative and, where 
feasible, quantitative assessment of their costs and benefits from administrative, economic, 
environmental, social and governance perspectives. 

Throughout  this  document,  actions  derived  from  the  Commission’s  announcement  of  22 
February 2024, including legislative proposals or delegated and implementing acts, are referred 
to hereafter as ‘the simplification package’. 

2.  POLITICAL AND LEGAL CONTEXT  

The reformed CAP for 2023-2027 

The CAP for 2023-2027 aims to foster a smart, competitive, resilient and diversified agricultural 
sector  that  ensures  our  long-term  food  security.  It  also  aims  to  support  and  strengthen 
environmental  and  climate  protection,  and  to  strengthen  the  socio-economic  fabric  of  rural 
areas.   

1  https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1002  
2  COM(2024) 139 final.  
3  Regulation (EU) 2021/2115 of the European Parliament and of the Council of 2 December 2021 establishing 
rules on support for strategic plans to be drawn up by Member States under the common agricultural policy 
(CAP Strategic Plans) and financed by the European Agricultural Guarantee Fund (EAGF) and by the European 
Agricultural Fund for Rural Development (EAFRD) and repealing Regulations (EU) No 1305/2013 and (EU) 
No 1307/2013, OJ L 435, 6.12.2021, p. 1 (CSP Regulation) and Regulation (EU) 2021/2116 of the European 
Parliament  and  of  the  Council  of  2 December  2021  on  the  financing,  management  and  monitoring  of  the 
common  agricultural  policy  and  repealing  Regulation  (EU)  No 1306/201,  OJ  L  435,  6.12.2021,  p.  187-261 
(Horizontal Regulation). 

4  Regulation  (EU)  2024/1468  of  the  European  Parliament  and  of  the  Council  of  14  May  2024  amending 
Regulations  (EU)  2021/2115  and  (EU)  2021/2116  as  regards  good  agricultural  and  environmental  condition 
standards, schemes for climate, environment and animal welfare, amendment of the CAP Strategic Plans, review 
of the CAP Strategic Plans and exemptions from controls and penalties, OJ L 2024/1468, 24.5.2024. 

5  COM(2023) 168 final. 

3 

 
 
 
At operational level, 28 CAP Strategic Plans6 (CAP Plans7) were drawn up by the Member 
States,  approved  by  the  Commission  and  first  applied  in  2023.  A  set  of  requirements, 
interventions  and  targets  across  10  CAP  specific  objectives  detail  the  abovementioned 
ambitions of the CAP, measured by common indicators. In combination with EU regulatory 
initiatives, research, investments and other actions to meet the EU’s environmental and 2050 
climate objectives, the CAP Plans contribute to the Commission’s Green Deal agenda.  

Compared to period before 2023, the reformed CAP represents a shift towards a performance-
based  model,  aiming  for  a  more  strategic  and  targeted  planning  (the  new  delivery  model, 
NDM). It is also a step forward in terms of simplification and increased flexibility.  

Bringing direct payments, sectoral and rural development types of interventions encompassing 
two funds8 under a single strategic tool (CAP Plans) was a major change to the CAP. Member 
States  gained  greater  flexibility  to  design  and  target  their  interventions  to  best  address  their 
specific circumstances, thus improving consistency and complementarity of how the funds are 
spent.  Under  this  approach,  Member  States  play  a  key  role  in  keeping  the  administrative 
burden  for  farmers  limited  and  proportionate.  The  new  approach  also  posed  certain 
challenges in ensuring common standards, and that efforts were comparable and aligned with 
each other. Any successful simplification that sustains the ambition of a high level of collective 
effort  requires  close  cooperation  between  the  Commission,  the  administrations  in  Member 
States and the farmers themselves.  

The 2024 simplification agenda 

The Commission’s 2023 assessment of the CAP Plans’ joint effort and collective ambition 
in  addressing  the  CAP’s  objectives9  concluded  that  the  new  approach  was  appropriate  to 
pursue the policy objectives but signalled the need to keep the administrative burden under 
review.  

While the new approach is working well overall, the first year of operation of the CAP Plans 
made it clear that adjustments were necessary to ensure that they bring the expected effects 
and to cut red tape. The first year also showed that there is a need to take better account of the 
impacts of Russia’s war of aggression against Ukraine, which strongly influenced the markets 
(and  farmers’  margins),  as  well  as  the  overall  context  for  the  EU’s  agricultural  policy.  The 
discussions on several related Green Deal legislative proposals were also relevant as they may 
affect  both  farmers  and  the  requirements  set  out  in  the  CAP  Plans.  The  reasons  for  the 
widespread protests by farmers in early 2024 are complex but reflected these concerns, as 
well  as  other  major  structural,  economic  and  climatic  challenges  in  agriculture  and  in  rural 
areas.  

The European Council of 1 February 2024 discussed the challenges in the agricultural sector, 
including the concerns raised by farmers during the protests. Stressing the essential role of the 
CAP, it called on the Council and the Commission to take the work forward as necessary.  

Commission President Ursula von der Leyen committed to launch a thorough analysis of the 
administrative  burden  on  farmers  to  identify  areas  for  improvement.  Based  on  input  from, 

6  Member States have one Strategic Plan each, except Belgium, which has two: one for Flanders and one  

for Wallonia. 

7  Sometimes also referred to as ‘CSPs’. 
8   The European Agricultural Guarantee Fund (EAGF) and the European Agricultural Fund for Rural Development 

(EAFRD).  

9  COM(2023) 707 final. 

4 

 
 
 
among others, the Member States, EU farmers’ organisations and the European Parliament, the 
Commission came forward with a non-paper on possible simplification actions on 22 February 
2024 as an input to Council discussions (‘the simplification package’).  

The Agriculture and Fisheries (AGRIFISH) Council of 26 February 2024 confirmed its political 
will to respond effectively to the concerns of farmers and, as a first step, supported a range of 
measures in the Commission’s simplification package as a priority for the short-term response. 
It  also  insisted  that  a  review  of  the  CAP’s  basic  acts  is  necessary  as  soon  as  possible. The 
Committee on Agriculture and Rural Development of the European Parliament also discussed 
the simplification package on 26 February10. 

On 15 March 2024 the Commission proposed to change certain provisions of the CAP related 
to the implementation and management of CAP Plans and certain instruments for environment 
and  climate.  Following  the  approval  of  the  European  Parliament  and  the  Council  with  no 
modifications  on  substance,  the  adopted  legislation  was  published  on  24  May  202411  (the 
Simplification Regulation). Several other legislative and non-legislative actions set out in the 
simplification package have also been completed or are underway. 

Reducing  the  administrative  burden  of  EU  policies  is  a  Commission  priority  since  it  is 
considered  crucial  to  the  EU’s  competitiveness12.  Simplification  of  EU  policies  affecting 
agriculture is a concern, both at EU and national level, and a number of short-term measures to 
rationalise reporting requirements were already being prepared before January 2024. The parts 
of the simplification package that will help reduce reporting obligations have been integrated 
into the rationalisation plan of the Commission’s Directorate-General for Agriculture and Rural 
Development (DG AGRI). Further actions may be added at a later stage.  

Related activities 

During their protests, farmers raised concerns about the fairness of the remuneration for their 
work, an issue that was also raised in debates with Member States, the European Parliament’s 
Committee on Agriculture and Rural Development and stakeholders. Farmers also complained 
about unfair competition from agricultural products from non-EU countries, which do not apply 
the same standards during the production process. Along with the simplification package, on 
15  March  2024,  the  Commission  presented  several  options  to  address  this  challenge  by 
improving  farmers’  position  in  the  agri-food  supply  chain13  and  protecting  them  against 
unfair trading practices. The Commission presented these options to the AGRIFISH Council on 
26 March 2024. Implementation of these actions is already underway. 

To provide a long-term perspective to farmers, on 25 January 2024 President von der Leyen 
launched the Strategic Dialogue on the Future of Agriculture in the EU14. It gathered actors 

10  https://multimedia.europarl.europa.eu/en/webstreaming/committee-on-agriculture-and-rural-

development_20240226-1900-COMMITTEE-AGRI  

11  Regulation  (EU)  2024/1468  of  the  European  Parliament  and  of  the  Council  of  14  May  2024  amending 
Regulations  (EU)  2021/2115  and  (EU)  2021/2116  as  regards  good  agricultural  and  environmental  condition 
standards, schemes for climate, environment and animal welfare, amendment of the CAP Strategic Plans, review 
of the CAP strategic plans and exemptions from controls and penalties, OJ L, 2024/1468, 24.5.2024. 

12  As highlighted in the Communication on the Long-term competitiveness of the EU: looking beyond 2030,    
   COM(2023) 168 final of 16 March 2023, https://commission.europa.eu/system/files/2023-

03/Communication_Long-term-competitiveness.pdf. 

13 Press release https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1493; Questions and Answers   

https://ec.europa.eu/commission/presscorner/detail/en/QANDA_24_1494.  

14  https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal/agriculture-and-

green-deal/strategic-dialogue-future-eu-agriculture_en  
5 

 
 
 
across the whole agri-food supply chain, as well as non-governmental organisations and civil 
society  representatives,  financial  institutions,  and  researchers.  By  combining  different 
perspectives, the dialogue aimed to foster the creation of new solutions and to bring about a 
common  vision  for  the  future  of  agriculture  in  the  EU.  This  dialogue  resulted  in  a  report 
delivered on 4 September 202415, in time for the new College, which took office on 1 December 
2024, to prepare its priorities. 

3. CONSULTATION STRATEGY AND EVIDENCE GATHERING 

3.1. Consultation of EU farming organisations, Member States, and the Committee on 
Agriculture and Rural Development of the European Parliament 

In  view  of  the  widespread  farm  protests,  the  Commission  asked  four  main  EU-level 
organisations  representing  farmers  to  suggest  measures  at  EU  level  (CAP  and  other  EU 
legislation)  to  reduce  the  administrative  burden  weighing  on  farmers’  shoulders. A  similar 
request  was  made  by  the  Belgian  Presidency  of  the  Council  to  agriculture  ministers.  
The European Parliament’s Committee on Agriculture and Rural Development also informed 
the Commission of the areas that it considered needed concrete and immediate action.  

The urgency of the situation meant that it was not possible to conduct the more usual, wider 
consultation process. This ad hoc consultation process lasted one week and resulted in a wide 
range of suggestions that fed into the Commission’s reflections on the scope and focus of the 
measures to take.  

•  The responses from Member States were wide in scope, with some citing practical 
challenges  that  could  feasibly  be  addressed  in  the  short  term,  while  many  other 
responses  were  far-reaching  and  went  beyond  the  issues  of  reduction  of  the 
administrative  burden,  simplification  of  implementation  or  a  stable  and  consistent 
policy framework for farmers.  

•  The  consultation  of  farming  organisations  resulted  in  calls  for  urgent  action  to 
simplify the administrative burden on farmers, but also stressed the need for a stable 
and consistent policy framework, proposing further reforms for the longer-term.  

•  Similarly,  the  European  Parliament’s  Committee  on  Agriculture  and  Rural 
Development identified several priority areas of work. These included suggestions to 
simplify procedures for the Commission to approve amendments of CAP Plans, and to 
make  certain  environmental  rules  more  flexible.  Other  suggestions  were  aimed  at 
improving the competitiveness of EU farmers, such as promoting mirror clauses in all 
trade agreements, revising the Unfair Trading Practices (UTP) Directive, improving the 
situation of farmers in the agri-food supply chain also by looking at competition rules, 
and carrying out an assessment of Green Deal legislation related to agriculture.  

Section 4 and Annex 2 summarise these suggestions and provide the Commission’s assessment. 

3.2. Consultations specific to individual measures  

On  several  individual  measures  of  the  simplification  package,  the  Commission  organised 
exchanges  and  consultations  involving  experts  from  all  27  Member  States  either  within  the 

15 https://agriculture.ec.europa.eu/document/download/171329ff-0f50-4fa5-946f-

aea11032172e_en?filename=strategic-dialogue-report-2024_en.pdf  

6 

 
 
 
Common Agricultural Policy Committee set up under the CAP Plan Regulation, or the Expert 
Group on the implementation of the CAP Plans.  

These consultations concerned: (i) the modifications related to GAEC 1 (19 February 2024); 
(ii) the revised IACS quality assessment methodology (18 March 2024); (iii) the clarifications 
on force majeure  (9 April 2024);  (iv)  the simplification of  the process  to amend  CAP Plans  
(9 April 2024); (v) workshop on control rationalisation (26 April 2024); (vi) the clarification 
note on the use of geotagged photos (15 May 2024); (vii) the revision of the requirement linked 
to geotagged photos (5 June 2024, 11 July 2024); (viii) the content of the CAP Plans and the 
provision  of  information  for  monitoring  and  evaluation  (5  and  28  June  2024);  (ix)  control 
statistics and control data on cross-compliance (28 June 2024, 11 July 2024). 

These activities gave the Commission the opportunity to present the context of its proposed 
measures, to explain the reasons for the relevant modifications or clarifications, and to exchange 
views with experts and to refine the measures where necessary. 

3.3. Gathering further evidence 

The simplification package announced two studies. Both are being carried out by contractors 
engaged by the Commission, and are described below: 

Study on simplification and the administrative burden for farmers under the CAP. 

This  study  is  examining  the  complexities  that  farmers  must  deal  with  as  regards  funding 
applications, monitoring, checks and environmental/sanitary requirements under the CAP and 
the  associated  EU  legislation.  It  takes  a  four-step  approach:  (i)  a  targeted  questionnaire  to 
farmers;  (ii)  follow-up  in-depth  interviews  with  300  selected  farmers;  (iii)  interviews  with 
farmers’ organisations; and (iv) an analysis to disentangle the sources of complexity for farmers 
between the EU and national levels, and between CAP and other requirements and policies, and 
to identify areas where the administrative burden can be reduced. The study is expected to be 
completed  by  early  2025.  It  will  feed  into  the  reflection  on  developing  and  implementing 
simplification actions.  

The  Commission  made  the  questionnaire  ‘Simplification  –  the  farmers’  point  of  view’ 
available in all official languages through the EU survey platform from 7 March until 8 April 
2024.  It  included  23  questions  on  the  profile  of  the  respondents  and  on  issues  related  to 
obligations and administrative procedures, particularly as regards applications for CAP support, 
record keeping and reporting, and on-site checks. Respondents were also asked to suggest ways 
to simplify the CAP.  

Nearly 27 000 replies were received, of which 80% were from farmers who have applied for 
CAP support, in all Member States. Preliminary results of the closed questions, including an 
overview  of  the  geographical  coverage  of  the  survey,  were  published  in  mid-April  202416  
(Box 1). These preliminary results echo some of the issues raised in the ad hoc consultations 
with Member States and other stakeholders (see Section 4 and Annex 2). An extensive analysis 
of the replies,  including  the  open questions, is  ongoing,  with  the results expected  by end of 
2024. The in-depth interviews with farmers, which took place in spring 2024, will be helpful to 
understand the rationale and background of the replies provided in the survey.  

16 https://agriculture.ec.europa.eu/news/simplification-survey-sheds-light-specific-issues-faced-farmers-across-

eu-2024-04-12_en  

7 

 
 
 
Box 1: Survey of the administrative burden on farmers - main preliminary findings. 

•  The process of applying for CAP support and respecting the mandatory requirements and 
conditions of the voluntary measures of the CAP are generally perceived to be overly 
complicated.  

•  33%  of  farmers  applying  for  CAP  support  spend  six  or  more  days  per  year  on 
administrative  tasks  linked  to  their  application,  including  preparing  the  necessary 
documents on conditionality. 

•  78% use some type of outside help to prepare and submit their CAP support applications. 

•  36% were contacted by the authorities  (‘early warning’) so that they can correct their 

CAP support applications to avoid penalties. 

•  Half of the farmers applying for CAP support use mobile devices to provide geotagged 
photos to the relevant authorities. Half of those farmers indicate concerns with the use of 
this technology (main concerns: the time it takes, not easy to use, lack of feedback on the 
accuracy of the pictures provided). 

•  Farmers  record  various  types  of  information  (obligatory  or  for  own  use),  mainly  by 
manual means. Automatic recording  is used rarely.  Most commonly, recording covers 
production, the use of fertilisers and pesticides, and soil analysis. 

•  Nearly  half  of  the  farmers  said  they  had  been  asked  to  provide  the  same  piece  of 
information more than once. This included requests related to tax and financial issues, 
requests for information on land use or its allocation or for environmental data. 

•  69% of respondent farmers had received at least one on-site inspection in the last 3 years. 

These visits may also include inspections not related to the CAP.  

•  Preparing and following up on these on-site checks required between half a day and one 

day of work for 63% of the farmers who were checked. 

Figure  1  Survey  of  farmers  ‘Simplification  –  the  farmers’  point  of  view’:  perceptions  of 
complexity linked to GAEC standards (% of respondents – farmers applying for CAP support) 

Note: Complexity may be linked to understanding, clarity of rules, length of the process, technical difficulties or 
other  issues.  Multiple  replies  where  possible  including  “No  opinion”  /  I  did  not  apply”  (i.e.  not  concerned). 
Therefore, where respondents indicated that they had no opinion/did not apply the GAEC the other view(s) that 
they may have expressed on that GAEC standard are not accounted for. 

8 

 
 
 
 
Study on the administrative burden on national authorities and the impact of the ‘new 
delivery model’ of the CAP.  

The study is set to carry out an assessment of the new delivery model (NDM) of the CAP in 
2023-2027. It will analyse the extent to which the NDM supports a more results-oriented CAP, 
strategic planning, and an improvement in the governance system. It will also assess whether 
the CAP Plan approval  process  and the safeguards set out in the regulations and procedures 
ensure that the ambitions of a Member State are proportionate to its needs and to equal treatment 
of  Member  States.  In  addition,  the  study  will  examine  the  burdens  and  costs  that  the  CAP 
imposes  on  administrations  at  the  different  stages  of  implementation  (including  design, 
consultation,  approval  and  amendments,  setting  up  and  running  CAP  Plans,  enforcement, 
reporting and evaluation), and the ways to simplify the implementation of the CAP.  

This  study  was  launched  in  August  2024  and  its  results  will  feed  into  the  reporting  and 
evaluation deliverables laid down in the CSP Regulation17.  

4.  OPTIONS  CONSIDERED  AND  THE  CHOICE  OF  INSTRUMENTS  FOR  THE 
SELECTED SOLUTION  

The suggestions received during the ad hoc consultation process (Section 3.1) fall under the 
five broad areas presented below. In planning and designing the responses to the suggestions, 
the Commission  took  into account:  (i)  the expectations of farmers and Member States  for a 
simpler and less burdensome CAP; (ii) the necessity to maintain the CAP’s role in supporting 
the  transition  of  the  EU  agriculture  to  sustainable  farming;  (iii)  the  nature  of  the  problems 
identified; and (iv) for legislative matters, the objective to quickly reach an agreement between 
the European Parliament and the Council, so that farmers could already benefit from some of 
the changes in 2024. A more detailed assessment of these suggestions is provided in Annex 2. 

4.1. CAP strategic plans: management, administration and controls  

This area includes the procedures to amend CAP Plans (including the increase in the maximum 
number of requests for amendment per calendar year) and the level of detail of the CAP Plans. 
It also covers elements of the integrated administration and control system (IACS), including 
the IACS quality assessment methodology, the use of geotagged photos, as well as the control 
and penalty systems for conditionality and for payments under interventions. Another group of 
suggestions concerns the simplification of the annual performance review (APR) which is the 
reporting  tool  to  track  the  CAP  Plan’s  performance.  Other  suggestions  concern  the  CAP’s 
methods  of  financing,  including  to  facilitate  transfers  between  the  funds.  Other  suggested 
changes concern the definitions in the CSP Regulation delimiting CAP support. 

In response, the Commission included a few targeted initiatives in the proposal of 15 March 
amending  the  EU’s  CAP  legislation,  in  particular  to  enable  Member  States  to  submit  more 
requests for amendments of CAP Plans and to eliminate conditionality controls and penalties 
for small farmers (farms up to 10 hectares). Other actions in the simplification package tackle 
issues of control burden, such as making the use of geotagged photos under the AMS voluntary 
(see Section 5.1). The Commission also launched discussions in relation to the requirements of  
the annual performance clearance. 

While  those  adjustments  aim  to  facilitate  processes  and  the  administration  of  the  CAP,  the 
Commission did not consider suggestions that would alter the new delivery model of the CAP 

17 Article 141 of the CSP Regulation. 

9 

 
 
 
more fundamentally. This new system was  introduced by the  co-legislators only as of claim 
year 2023, and further experience of its implementation and an assessment of its functioning 
are  necessary.  In  contrast,  a  number  of  other  suggestions  promoting  greater  flexibility  for 
Member States can already be addressed within the current legal framework, for example as 
regards  the  organisation  of  controls  and  the  penalty  system,  including  the  introduction  of  a 
single control of agricultural holdings and the level of sanctions, as long as they comply with 
the EU requirements. For certain other suggestions, such as the level of detail in the CAP Plans, 
the lessons learned from the current period will feed into the reflection on the post-2027 CAP 
and the work on future EU legislation. 

4.2. CAP strategic plans: the green architecture  

These suggestions concern the various CAP Plan tools to implement the objectives of the CAP 
in relation to the environment and climate18, often together referred to as the ‘green architecture’ 
of the CAP Strategic Plans. Many suggestions concerned targeted changes to ‘conditionality 
requirements’ (the basic layer of the ‘green architecture’) but other suggestions were also made, 
e.g.  exempting  small  and  organic  farms  from  conditionality  requirements,  or  changing  the 
financial management of environmental interventions.  

As a preliminary step to addressing the concerns underlying these suggestions, the Commission 
had adopted a temporary and partial derogation from the first requirement of GAEC standard 8 
for  claim  year  2024  (on  the  share  of  non-productive  areas/features  on  arable  land)19,  and 
adjusted the rules for GAEC standard 1 on the calculation of the permanent grassland ratios and 
reconversion obligations (see Section 5.2)20. 

Further modifications  followed with  the  amendments  to the CSP Regulation  and  Horizontal 
Regulation  as  part  of  the  simplification  package.  They  contained  targeted  adjustments  to 
conditionality  rules  that  aimed  to  address  implementation  concerns  for  several  GAEC 
standards, and controls and penalties for small farmers (see Sections 5.1 and 5.2).  

The Commission opted for this rebalancing in the direction of a more voluntary approach to 
keep  the  overall  policy  objectives  supporting  the  transition  to  sustainable  agriculture  and  to 
maintain the set of instruments of the CSP Regulation as decided by the co-legislators in 2021. 
It  considered  that,  in  general,  GAEC  requirements  cover  the  basic  practices  backed  by  the 
general  agronomic  consensus  and  are  appropriate  to  address  the  relevant  needs  across  all 
farming systems. Additionally, these requirements mostly prolong or reinforce the requirements 
that  already  applied  to  all  farmers  before  2023.  It  is  true,  however,  that  some  new  GAEC 
standards introduced in 2023 made the conditionality rules much more demanding than in the 
previous period, or included practices that used to be remunerated under the previous CAP and 
that have cost implications for farmers’ income.  

18 Articles 5 and 6 of the CSP Regulation. 
19 Commission Implementing Regulation (EU) 2024/587 of 12 February 2024 providing for a derogation from 
Regulation (EU) 2021/2115 of the European Parliament and of the  Council as regards the application of the 
standard for good agricultural and environmental conditions of land (GAEC standard 8), dates of eligibility of 
expenditure  for  contribution  from  the  EAGF  and  rules  concerning  amendments  of  CAP  strategic  plans  for 
modifications of certain eco-schemes for claim year 2024, OJ L 2024/587, 13.2.2024. 

20  Commission  Delegated  Regulation  (EU)  2024/1235  amending  Delegated  Regulation  (EU)  2022/126  of 
12 March 2024 supplementing Regulation (EU) 2021/2115 of the European Parliament and of the Council as 
regards the rules on the ratio for the good agricultural and environmental condition (GAEC) standard 1, OJ L 
2024/1235, 26.4.2024. 

10 

 
 
 
4.3. Farm income and competitiveness  

This  area  reflects  concerns  about  farm  income,  with  suggestions  to:  (i)  revise  the  CAP 
provisions  on  risk  management  instruments  and  to  allocate  more  CAP  funds  to  crisis 
management;  (ii)  expand  coupled  support,  or  adjust  the  sectoral  support  schemes  or  their 
financial management; (iii) change the rules on investments; (iv) and take action to improve the 
position of farmers in the agri-food supply chain.  

The Commission shares the concerns related to farm income and proposed measures to improve 
the position of farmers in the agri-food supply chain and to protect them against unfair trading 
practices in the separate reflection paper of 15 March 2024. Work is ongoing on putting the 
ideas in this paper into practice (see Section 5.3).  

The Commission is examining the feasibility and the impact of certain limited adjustments to 
the  CAP  framework,  addressing  farmers  who  are  acting  together,  that  could  respond  to  the 
concerns behind the suggestions received. However, the vast majority of the suggested changes 
to the CAP would entail fundamental policy changes, and therefore pertain to the reflection on 
the CAP after 2027. Some suggestions were also not taken up because they were deemed to 
hamper the achievement of the policy objectives of the CAP Plans. Some suggestions may be 
covered by the contemplated targeted changes to the Regulation on the common organisation 
of markets in agricultural products21. 

4.4. Other CAP instruments 

This  area  covered  other  elements  of  the  EU  CAP  legal  framework  such  as  postponing  or 
removing social conditionality, and other instruments of the CAP, such as reducing the variables 
to be collected under the Farm Sustainability Data Network (FSDN), promotion measures, the 
EU school scheme, marketing standards and organic farming. Other suggestions called for a 
more fundamental rethink of EU agricultural policy, such as making CAP Plans more strategic.  

Many  of  these  suggestions  went  beyond  the  remit  of  simplification  and  the  improved 
implementation of the CAP Plans. The Commission took the view that the key elements of the 
CSP  Regulation,  such  as  social  conditionality  should  be  maintained.  The  Commission  also 
considered that several suggestions, such as the level of detail on measures required in the CAP 
Plans, were already feasible within the increased flexibility for the Member States in the new 
delivery model of the CAP. 

4.5. Legislation outside the CAP 

The final set of suggestions concerned legislation outside the CAP, in the areas of State aid, 
environment, animal and plant health, food safety, climate and energy.  

In its simplification package the Commission announced a number of targeted changes in acts 
outside the CAP and  is  working  on non-legislative measures with  the aim  of simplifying or 
clarifying  certain  rules.  On  2  May  2024,  the  Commission  also  launched  the    review  of  the 
agricultural de minimis Regulation22. These rules were last revised in 2019 and were originally 
set to expire at the end of 2027. Their revision was brought forward and accelerated in light of 
the inflationary pressure in recent years and the current context with, among other things, high 

21  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 and repealing Council Regulations 
(EEC) No 922/72, (EEC) No 234/79, (EC) No 1037/2001 and (EC) No 1234/2007, OJ L 347, 20.12.2013, p. 
671-854. 

22 https://ec.europa.eu/commission/presscorner/detail/en/ip_24_2332  

11 

 
 
 
commodity prices affecting the agricultural sector. On 7 June 2024, the Commission launched 
a public consultation, which ended on 21 July 2024 seeking feedback from stakeholders on its 
proposal  for  a  draft  amendment23.  For  a  number  of  other  legislative  proposals,  policy 
simplification can still be addressed during the ongoing legislative procedures as explained in 
Annex 2. 

For  certain  other  suggestions,  such  as  the  consistency  between  laws  affecting  farmers,  the 
lessons learned from the current period will feed into the reflection on the post-2027 CAP and 
the work on relevant future EU legislation. 

Certain comments referred to the ongoing evaluation of the Nitrates Directive and suggestions 
were made for a temporary exemption  that would enable the safe use of RENURE products 
(recovered  nitrogen  from  manure)  in  Nitrates Vulnerable  Zones  beyond  the  current  limit  of  
170 kg N/ha/year from manure, based on RENURE criteria developed by the Commission’s 
Joint Research Centre, and which could substitute the use of chemical fertilisers.  Awaiting the 
outcome of the evaluation, an interim solution that would allow RENURE products to be used  
has been prepared by the Commission and, at the time of writing, is pending opinion of the 
Member States in the Nitrates Committee24 and the scrutiny of the co-legislators before coming 
into law.  

5. DESCRIPTION OF THE ACTIONS TAKEN 

5.1 CAP Plans: management, administration and controls 

Improving the procedure to amend CAP Plans   

The  handling  and  management  of  amendments  to  CAP  Plans  is  a  joint  process,  requiring  a 
partnership between the Commission and Member States’ administrations to ensure a successful 
outcome. Building on the experience of the first year of implementation of the CAP Plans, the 
Commission reviewed the procedure for assessing and approving amendments to CAP Plans.  

In its proposal of 15 March 2024, the Commission doubled the maximum number of requests 
for amendments that Member States may make per calendar year (from one to two) so that 
Member  States  can  adapt  their  support  measures  to  changing  conditions  and  farmers’  needs 
more frequently and in a more targeted way.  

On  5  April  2024  the  Commission  communicated  to  Member  States  that  it  had  agreed  to 
streamline the approval process of  amendments to CAP Plans and presented the changes on 9 
April 202425.  In line with the greater subsidiarity, flexibility, and performance orientation of 
the  2023-2027  CAP,  the  Commission  services  are  committed  to  continue  taking  a  ‘need  to 
know’  approach  for  the  assessment  of  requests  for  amendments,  and  of  notifications  of 
changes to rural development interventions26:  

•  The  level  of  detail  of  the  information  requested  from  national  authorities  will  be 
proportionate  to  the  nature  of  the  modification,  focusing  on  essential  and  legally 
required information necessary to understand and assess the proposed changes.  

23 https://competition-policy.ec.europa.eu/public-consultations/2024-deminimis-agri_en  
24 https://ec.europa.eu/transparency/comitology-

register/screen/meetings/CMTD%282024%29772/consult?lang=en  

25 https://ec.europa.eu/transparency/expert-groups-register/screen/meetings/consult?lang=en&meetingId=53235  
26 Article 119 of the CSP Regulation. 

12 

 
 
 
•  Where  it  is  obvious  from  the  description  of  the  amendment  or  change,  additional 
justifications  that  the  change  does  not  affect  targets  and  milestones  under  the  result 
indicators will not be requested.  

•  Member States will not be asked to confirm that they respect the EU legal framework 

where an amendment does not contain any indication of non-compliance.  

As  regards  the  Member  States,  streamlining  the  approval  process  will  require  a  realistic 
planning of requests for amendments, and a clear and focused description of the amendments 
and  accompanying  justifications  that  avoids  unnecessary  details.  Member  States  are  also 
encouraged to simplify the description of the interventions in their amendments of CAP Plans 
in the future. An open, constructive, and transparent informal dialogue between the Commission 
and  national  authorities,  based  on  advance  information  on  the  proposed  amendments,  helps 
speed up the approval process. Timely planning of amendments helps manage expectations and 
avoid unnecessary modification proposals.  

Controls for conditionality and cross compliance 

Concerns had also been raised about the proportionality and burden of conditionality checks 
and penalties, especially for smaller farms. The rules on controls of conditionality are laid down 
in EU legislation, which requires that 1% of farmers must be controlled every year. To address 
the burden of control in this area, on 15 March 2024 the Commission proposed to exempt small 
farms  of  under  10  hectares  of  agricultural  area  from  controls  and  penalties  related  to 
conditionality requirements. While controls of conditionality no longer apply for these farms, 
they  are  not  exempted  from  the  conditionality  requirements  which  also  continue  to  be  the 
baseline for other CAP interventions like eco-schemes. 

There is a group of beneficiaries under the 2023-2027 CAP who continue to receive area-based 
rural development support from the pre-2023 CAP. The payments for these voluntary measures 
are  subject  to  the  previous  ‘cross-compliance’  system  in  place  in  2014-2022. To  reduce  the 
control  burden  on  farmers  who  are  subject  to  both  conditionality  and  cross-compliance  the 
Commission  also  proposed  on  15  March  to  exempt  these  farmers  from  cross-compliance 
controls and penalties and to rely solely on conditionality. 

Reporting on the results of cross-compliance controls 

In  line  with  the  Commission’s  aim  to  rationalise  and  simplify  reporting  requirements  for 
administrations and given the very limited representativeness of the sample used in reporting 
on control data and control statistics for cross-compliance, the Commission decided to waive 
the obligation for Member States to submit these figures for claim years 2023, 2024 and 202527. 
This modification will apply retroactively from 1 January 2024 to cover the 2023 figures, which 
Member States were obliged to transmit from 15 July 2024. 

Rationalising controls, including the right of error  

The integrated administration and control system (IACS)28 helps Member States to manage, 
monitor  and  control  all  the  area  and  animal-based  CAP  interventions,  and  ensures  that 
comprehensive and comparable EU data is available. 

27 eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=PI_COM:C(2024)6069&qid=1725451340160 
28 https://agriculture.ec.europa.eu/common-agricultural-policy/financing-cap/assurance-and-audit/managing-

payments_en  

13 

 
 
 
The IACS consists of several elements, integrating information captured, for example, by the 
Copernicus Sentinel satellites as part of the area monitoring system (AMS) used to observe, 
track and assess agricultural activities on all hectares claimed under area-based interventions29. 
A key part of the system is the Geo-spatial application (GSA) that allows CAP beneficiaries to 
visually  identify  the  areas  claimed  for  help  in  their  online  aid  application.  Member  States 
subsequently monitor agricultural activities and check compliance with eligibility conditions 
using the AMS.  

For the relevant interventions, IACS helps Member States to keep track of the performance of 
the CAP and helps to protect the EU’s financial interests, by helping beneficiaries to make CAP 
aid  applications (applications for CAP support) correctly  and by preventing non-compliance 
with  the  associated  obligations. The  IACS  contains  the  necessary  data  to  feed  into  Member 
States’ annual performance reports (on the progress in implementing their CAP Plans).  

Member States are responsible for setting up management and control systems and decide how 
often checks should be carried out. The EU-level principles and requirements for these systems 
are much less detailed than in the previous CAP periods.  

To support Member States in rationalising their control systems, the Commission organised 
a  workshop  on  26 April  2024  to  clarify  how  the  EU-level  rules  should  be  applied  and  to 
exchange best practices among Member States. These are some of the main issues discussed: 

•  The Commission reminded Member States that their management and control systems 
should  include  the  possibility  for  beneficiaries  to  amend  or  correct  their  aid 
application or payment claim after submission. Such corrections should be possible 
until the moment when the applicant is informed that they have been selected for an on-
the-spot  check,  or  when  the  competent  authority  has  taken  its  decision  on  the 
application30.  

•  Specifically  for  area-based  interventions,  Member  States  are  required  to  inform 
farmers about non-compliance with eligibility conditions that were detected by the 
administrative  checks  or  by  the  AMS.  In  these  cases,  farmers  are  to  be  given  the 
possibility  to  amend  or  withdraw  the  aid  application.  To  facilitate  this  further, 
national  authorities  may  make  the  necessary  corrections  in  the  aid  application 
themselves.  In  such  a  case,  they  must  ensure  that:  (i)  the  farmers  are  aware  of  the 
changes; and (ii) that they have the possibility to react if they disagree with the change 
made. 

•  Combining  the  use  of  new  technologies  with  the  right  of  error  is  helpful  in  this 
context as IT systems can automatically inform farmers of potential errors, so they avoid 
penalties.  

•  This  allows farmers to  correct  their applications where  errors  were made or  adjust 
them based on realities on the ground. The goal is to help farmers avoid errors which 
can lead to non-implementation of the policies. In this way, penalties for farmers are 
avoided and the policy performance is improved. 

29 Other IACS elements include: the  land parcel identification system (LPIS) to identify agricultural parcels, a 
system  for  identification  of  beneficiaries,  a  control  and  penalty  system,  and  a  system  for  identification  and 
registration of animals in cases of CAP related aid. 

30 Article 7 of Commission Implementing Regulation (EU) 2022/1173 of 31 May 2022 laying down rules for the 
application of Regulation (EU) 2021/2116 of the European Parliament and of the Council with regard to the 
integrated administration and control system in the common agricultural policy, OJ L 183, 8.7.2022, p. 23-34. 
14 

 
 
 
•  However, controls must remain effective. Therefore, such warning messages cannot 
be sent after the applicant is informed or made aware of their selection for an on-the-
spot check.  

The workshop on rationalising controls also enabled Member States to share their experiences 
in  developing management  and control systems  that  alleviate the  administration and control 
burden  on  farmers  without  affecting  the  level  of  assurance  on  the  outputs  declared  for 
performance. 

Revision of the EU-level methodology for IACS quality assessment 

The main IACS components are subject to an annual quality assessment to evaluate if the IACS 
is achieving its aims, and to improve how it works (as regards the correct number of hectares 
for  the  CAP´s  output  and  result  indicators).  In  this  framework,  the AMS  and  GSA  quality 
assessments together provide diagnostic information on the sources of incorrect decisions at 
the level of interventions and eligibility conditions.  

The AMS  helps  reduce  the  administrative  burden  for  Member  States’  paying  agencies  and 
beneficiaries thanks to the automated process. These ensure that applications are correct, as 
beneficiaries can modify their applications after an early warning alert and encourage farmers 
to  comply  with  the  requirements  via  a  system  of  pre-warnings  to  be  implemented  by  the 
Member States. 

In response to Member States’ concerns about the burden of the quality assessment verifications 
linked to the AMS and the GSA, the Commission revised the EU-level methodology for the 
IACS quality assessment (published on 21 March 2024).  

The revised methodology aims to reduce Member States’ workload by revising the sampling 
approach,  making  it  possible  to  group  unit  amounts  among  different  interventions,  and  by 
introducing the possibility to cap at 3% the total number of holdings in the Member State to be 
included  in  the  quality  assessment  sample.  The  sampling  procedure  was  also  considerably 
improved  to  allow  Member  States  to  check  multiple  parcels  on  the  same  holding,  so  that 
multiple  checks  can  be  carried  out  during  the  same  field  visit.  This  sampling  procedure  is 
similar to the one historically used for the control system, which increases the scope to combine 
the quality assessment exercise with controls. 

Revision of the requirements linked to geotagged photos 

The use of geotagged photos was intended to reduce the control burden on farmers. Instead of 
relying on on-site visits, the farmer provides the authorities with a digital photograph of the 
geographic  position  that  shows  the  presence  or  absence  of  an  activity,  or  an  element  that  is 
subject to a legal requirement or is part of the voluntary commitment made by the farmer under 
the CAP.  

According to the EU rules31, some eligibility conditions such as nest protection, flower species 
diversity  and  animal  presence,  which  can  be  monitored  by  the  automatic  processing  of 
geotagged  photos,  had  to  be  covered  by  the AMS  by  2027. During  the  ad  hoc  consultation, 
Member States raised several concerns in this regard, such as the development, implementation 
and optimisation of algorithms to process geotagged photos, the costs of storing them and the 
shortage  of  qualified  staff.  For  these  reasons,  Member  States  asked  for  a  delay  in  the 

31 Article 10 of Commission Implementing Regulation (EU) 2022/1173. 

15 

 
 
 
introduction of geotagged photos, or that their use should be limited. The survey of farmers also 
revealed some concerns about their use, which was perceived as an additional burden. 

On 2 May 2024, the Commission shared with Member States a clarification note on geotagged 
photos,  which  was  discussed  with  Member  State  experts  on  15  May  202432.  The  note 
acknowledged the barriers identified by Member States and farmers and aimed to clarify the 
applicable provisions and outline the benefits of geotagged photos. The note proposed strategies 
to reduce the administrative burden associated with geotagged photos, including a review of 
the legal requirements. 

Following  up,  in  the  CAP  Committee  of  5  June  2024,  the  Commission  presented  a  draft 
amendment of the requirements on the use of geotagged photos to limit the burden on farmers 
and  increase  their  acceptability  and  use. The  amendment  also  aims to  reduce  the  burden  on 
Member States by  eliminating the requirement to incorporate  in the AMS interventions 
with eligibility conditions that can only be monitored by geotagged photos. Following a 
positive opinion by Member States in the CAP Committee, the Commission adopted the revised 
version of the amendment on 4 September 202433. 

Given the benefits of geotagged photos, the Commission does not prevent Member States from 
their usage. The flexible approach ensures that Member States that have already invested in this 
process will not experience setbacks in their progress and increases the possibilities for a swifter 
handling of the payment files of farmers who use geotagged photos.  

Clarification of the use of the force majeure and exceptional circumstances clause 

The concept of force majeure refers to abnormal and unforeseeable circumstances, outside the 
control  of  an  operator  (such  as  a  farmer),  the  consequences  of  which  could  not  have  been 
avoided despite taking all due care. Force majeure excuses such a farmer from certain legal 
consequences that would normally result from non-compliance. The decision to recognise force 
majeure is taken by the Member State authorities, based on the relevant evidence.  

On 30 May 2024 the Commission adopted a Communication to the Council on force majeure 
and exceptional  circumstances34 in  the Horizontal  Regulation. The Communication  clarifies 
the application of this concept, focusing on its application based on an area rather than on 
a case-by-case assessment. This responds to requests from Member States  for greater clarity 
about applying this concept and for greater certainty for farmers as regards their CAP support 
in such cases. 

The Commission has clarified that if severe natural disasters or severe meteorological events, 
such as flooding or fires, gravely affect a clearly defined area, a Member State may presume 
that the farmers in the area affected by the abnormal event, whose consequences could not be 
prevented with all due care, are covered by force majeure. The Member State may make this 
presumption provided that the determination of the area, of the population of farmers inside it, 
and where relevant, of the affected CAP obligations, is undertaken in such a way that makes it 
possible to conclude that the conditions of force majeure are individually met by the farmers 
concerned. 

32 https://ec.europa.eu/transparency/expert-groups-register/screen/meetings/consult?lang=en&meetingId=53804  
33 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=PI_COM:C(2024)6069&qid=1725451340160  
34  Communication  from  the  Commission  to  the  Council  on  force  majeure  and  exceptional  circumstances  in 
Regulation (EU) 2021/2116 of the European Parliament and of the Council on the financing, management and 
monitoring of the common agricultural policy, COM(2024)225 final. 

16 

 
 
 
5.2. CAP Strategic Plans: the green architecture  

Conditionality 

‘Conditionality’ requires that area- and animal-based CAP payments received by farmers are 
linked  to  the  respect  of  certain  requirements,  including  GAEC  standards35 in  the  areas  of 
climate  change,  water,  soil  and  biodiversity.  These  standards  are  defined  in  the  CAP  Plans, 
based on the framework and main objectives set out in the CSP Regulation.  

In  2023,  the  first  year  of  the  current  CAP  period,  farmers  encountered  difficulties  in  fully 
complying  with  some  of  these  requirements,  which  had  been  strengthened  compared  to  the 
previous period (2014-2022). The measures proposed by the Commission aim to address these 
challenges in a balanced and targeted way, according to the specificities and objectives of each 
standard.  

GAEC 1 (Permanent grassland) 

GAEC standard 1 requires Member States to maintain permanent grassland based on a (national 
or  regional  or  individual36)  ratio  of  permanent  grassland  to  agricultural  area  that  is  to  be 
compared  to  the  reference  year  2018.  Where  this  ratio  has  decreased  by  more  than  5%, 
the  Member  State  is  to  impose  obligations  to  establish  or  (re-)convert  land  into  permanent 
grassland at holding level for some or all of the farmers who have at their disposal areas which 
had  been  converted  from  permanent  grassland  to  other  uses.  Commission  Delegated 
Regulation37 lays down the rules to ensure a level playing field when establishing the ratios of 
permanent grassland in the application of GAEC 1. 

The amendment to this Delegated Regulation38, published on 26 April 2024, allows Member 
States to adjust the reference ratio once during the CAP programming period (2023-2027). This 
may be done to reflect post-2018 reductions in the area of permanent grassland due to structural 
changes in the farming system, thus substantially impacting the ability of farmers to maintain 
permanent  grasslands  while  maintaining  their  farms’  economic  viability.  When  imposing  
(re-)conversion obligations on farmers when the ratio fell below 5%, the adjustments also allow 
Member States to take into account the increase in total agricultural area declared by farmers 
in their CAP aid application, and areas of permanent grassland that exist39 but were not declared 
by them, as well as decreases due to the conversion of permanent grasslands to non-agricultural 
uses.  

GAEC 6 (Minimum soil cover) 

Under GAEC 6 Member States define requirements that ensure a minimum soil cover during 
the most sensitive periods to avoid bare soil and thus protect it against leaching, erosion and 
depletion of organic matter. Member States set out in their CAP Plans the most sensitive periods 
when a minimum soil cover is needed. There is a wide range of different types of minimum soil 
cover,  which  mostly  includes  crops,  green  cover,  stubble,  mulching,  plant  residues  or 
spontaneous vegetation. Sometimes farmers can do shallow tillage to mix the stubble with soil 

35 Articles 12-13 and Annex III to the CSP Regulation. 
36 As set by a Member State in its CAP Strategic Plan. 
37  Commission  Delegated  Regulation  (EU) No 2022/126  of  7 December  2021  supplementing  Regulation  (EU) 
2021/2115  of  the  European  Parliament  and  of  the  Council  with  additional  requirements  for  certain  types  of 
intervention specified by Member States in their CAP Strategic Plans for 2023-2027 under that Regulation, as 
well as rules on the ratio for GAEC standard 1, OJ L 20, 31.1.2022, pp. 52-94. 

38 Commission Delegated Regulation (EU) 2024/1235. 
39 That are registered in Member States Land Parcel Identification System (LPIS). 

17 

 
 
 
so  that  the  soil  stays  protected.  Some  Member  States  have  taken  voluntary  measures  that 
support  the  establishment  of  catch  crops  and  green  cover,  adding  further  benefits  to  the 
minimum soil cover under GAEC 6.  

The flexibilities in the CAP Plans included e.g. requiring coverage only on 80% of arable land, 
or specific provisions for heavy clay soil. It is important to note that under this GAEC there 
were no requirements regarding sowing dates, and that farmers always had the option to plough 
during  the  sensitive  period  if  it  was  for  the  purpose  of  sowing  in  the  following  weeks. 
Nevertheless,  further  flexibility  for  Member  States  was  considered  necessary  for  a  smooth 
implementation of GAEC 6, taking into account the variety of situations in the field and the 
contribution of the required practice to the objectives of the GAEC 6 standard.   

Despite the range of possibilities to meet the GAEC 6 standard, in some cases the rules have 
created practical problems, e.g. where it was impossible to establish and maintain certain soil 
cover  because  of  the  weather  situation,  creating  uncertainty  and  frustrating  farmers.  
In particular, when there was late harvesting on heavy soils (often unavoidable in wet autumns), 
GAEC 6 was seen as an obstacle to autumn ploughing, and forcing farmers to prepare the soil 
after winter, which entailed, in some cases, a risk of soil compaction. 

The Commission proposal of 15 March 2024 to amend the CSP Regulation added the words 
‘as determined by Member States’ to the definition of GAEC 6. This clarifies the responsibility 
of Member States and provides increased flexibility in determining  the key elements of this 
GAEC, in particular the timing and duration of ‘sensitive periods’ for which Member States 
‘may in particular take into account the short vegetation period resulting from the length and 
severity of the winter period in the regions concerned’. However, as specified in recital 15 of 
the proposal, ‘the Commission should ensure, in accordance with Articles 13(1) and 109(2) and 
Articles  118  and  119  of  that  Regulation,  that  the  GAEC  standard  6  as  determined  by  the 
Member States is, overall, in line with the main objective of that GAEC standard’.   

GAEC 7 (Crop rotation/diversification) 

GAEC  7  aims  to  protect  soil  potential  over  time  through  crop  rotation.  The  Commission’s 
proposal of 15 March 2024 added an option whereby Member States may allow farmers to fulfil 
GAEC 7 through diversification of crops on their farms within a given year. Certain farming 
realities and weather conditions  can make it difficult  for farmers to  ensure crop rotation  for 
example market demand for specific crops, seed availability and the windows for sowing certain 
crops. In 2023, Member States were permitted to grant a derogation from GAEC 7 in light of 
the impact that Russia’s war of aggression in Ukraine had on global food security. The aim was 
to ensure that farmers were not prevented from responding to the demand for food crops in line 
with the changing market context. 

GAEC 8 (Non-productive arable land) 

GAEC 8, which addresses biodiversity on farms, requires, among other things, that a minimum 
share  of  arable  land  at  holding  level  be  devoted  to  non-productive  areas  and  features  (‘the 
GAEC 8 first requirement’, 4% as a general principle) and that landscape features should be 
retained. As for GAEC 7, in 2023, Member States could allow farms to derogate from the first 
requirement of GAEC 8, again because of the impact on global food security of Russia’s war 
of aggression in Ukraine. 

The  GAEC  8  first  requirement  has,  however,  proved  costly  for  some  categories  of  farmers, 
particularly in view of the pressure on margins in certain arable crop sectors and in areas with 
high land prices. Farmers have therefore faced difficulties in complying with this requirement 

18 

 
 
without a direct compensation for the efforts made. The Commission therefore proposed on 15 
March  2024  to  replace  this  GAEC  8  requirement  with  an  obligation  for  Member  States  to 
establish  an  eco-scheme  offering  support  to  farmers  for  the  maintenance  of  non-productive 
areas, such as land laying fallow, and for the establishment of new landscape features, on arable 
land.  

Member States may decide to  remove the first  requirement of GAEC  8, as from  claim  year 
2024, if they have an eco-scheme which supports non-productive areas or the establishment of 
new landscape features, on arable land. Otherwise, Member States must apply this change from 
claim year 2025 at the latest.  

It  is  important  to  have  the  necessary  tools  in  place  to  address  the  objective  on  biodiversity. 
Adopting a tool that is voluntary for farmers, and which ensures adequate compensation for the 
commitment to maintain non-productive areas and establish new landscape features, on arable 
land,  makes  the  combination  of  mandatory  and  voluntary  tools  better  suited  to  the  current 
context.  

Specific exemptions from GAECs 5, 6, 7 and 9  

On 15 March 2024, the Commission also proposed that Member States may provide in their 
CAP  Plans  specific  exemptions  from  GAECs  5  (tillage),  6  (soil  cover),  7  (crop  rotation/ 
diversification) and 9 (ban on ploughing and converting environmentally sensitive permanent 
grasslands in Natura 2000 areas)40 to address specific problems in applying the requirements of 
those  standards  so  as  to  ensure  the  economic  viability  of  farms. These  problems  could,  for 
example, be due to particular agronomic situations for certain crops in particular soil types and 
pedoclimatic conditions, or because of the damage to permanent grasslands by wild animals or 
invasive species. The proposal also laid down that ‘The specific exemptions shall be established 
only  where  and  to  the  extent  that  they  are  necessary  to  address  specific  problems  in  the 
application of those standards and shall not significantly hamper the contribution of each of 
those standards to their main objectives’. 

Temporary and targeted derogations from conditionality requirements  

The  Commission  proposal  also  contained  provisions  enabling  Member  States  to  introduce 
temporary and targeted derogations41 from GAEC standards where, in  a given year, farmers 
would be prevented from complying with them due to weather conditions such as flooding or 
drought.  This  possibility  can  be  an  important  tool  to  balance  the  need  to  apply  the  GAEC 
standards  as  a  step  in  the  transition  towards  more  sustainable  farming,  with  the  need  for 
flexibility to navigate the changing  climate  context, which brings increasingly unpredictable 
weather conditions. 

Review of CAP Plans in case of changes to EU environmental and climate legislation 

In drawing up their CAP Plans, Member States had to take account of the analysis, objectives 
and targets of key EU environmental and climate laws (and plans stemming from these) listed 
in  Annex  XIII  of  the  CSP  Regulation.  The  CSP  Regulation  also  requires  Member  States  to 
review and update their CAP Plans when this is necessary to align them to changes in this EU 
legislation42. To avoid frequent changes to the CAP Plans and ensure stability in the support 
schemes for farmers, the Commission proposal of 15 March 2024 limits the application of this 

40 Article 1(2), point (a) of Regulation (EU) 2024/1468. 
41 Article 1(2), point (b) of Regulation (EU) 2024/1468. 
42 Article 120 of the CSP Regulation. 

19 

 
 
 
requirement  to  amendments  of  legislative  acts  in  Annex  XIII  that  enter  into  force  by  31 
December 2025 at the latest.     

5.3 Farm Income and competitiveness  

Position of farmers in the agri-food supply chain 

The Commission’s paper of 15 March 202443 lists several immediate, short-term and medium-
term  actions  to  strengthen  the  position  of  farmers  in  the  agri-food  supply  chain,  with  the 
ultimate goal of supporting their income and ensuring fair remuneration.  

The Commission has already delivered on some of these measures, starting with the set-up of 
the new EU Agri-Food Chain Observatory (AFCO)44. It brings together national authorities 
and  stakeholders  representing  all  levels  of  the  agri-food  supply  chain  with  the  purpose  of 
promoting  increased  transparency  on  prices,  the  structure  of  costs  and  the  distribution  of 
margins, as well as added value in the supply chain. The first two meetings of the new AFCO 
took place on 17 July and 15 October 2024. 

In addition, on 23 April 2024 the Commission published a report on the implementation of EU 
rules against unfair trading practices in the agri-food supply chain45. This report takes stock 
of the implementation of the Unfair Trading Practices (UTP) Directive46, and will feed into a 
more detailed evaluation of the Directive that the Commission will present in 2025. This could 
be  followed,  if  appropriate,  by  legislative  proposals  to  revise  the  Directive.  The  report  is 
accompanied  by  a  Staff  Working  Document  providing  further  information,  in  particular  on 
Member States’ transposition choices47. 

The Commission is also working on other actions to further correct imbalances in the agri-
food supply chain, which includes considering targeted changes to the Regulation establishing 
a common market organisation of agricultural products (CMO)48. This aims to strengthen 
farmers’  position  in  the  supply  chain,  including  e.g.  through  improved  rules  on  contracts,  a 
stronger  role  for  producer  organisations  and  their  associations,  and  measures  to  support 
voluntary approaches such developing short supply chains and fair-trade schemes.  

The Commission will propose new rules to improve the enforcement of the rules against unfair 
trading practices for cross border transactions. 

5.4 Other CAP instruments  

Exchange of best practices  

The  Commission  organises  exchanges  between  Member  States  of  best  practices  to  simplify 
interventions  and  minimise  the  administrative  burden  related  to  the  CAP  Plans.  One  of  the 
forums  where  these  exchanges  take  place  is  the  European  CAP  Network49,  which  brings 
together administrators, researchers, entrepreneurs, and practitioners to share knowledge and 

43 https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1493  
44  https://agriculture.ec.europa.eu/common-agricultural-policy/agri-food-supply-chain/afco_en 
45  COM(2024)176 ‘Implementing the prohibition of unfair trading practices to strengthen the position of farmers 

and operators in the agricultural and food supply chain – State of play’.    

46 Directive  (EU) 2019/633  of the European Parliament and of the  Council of 17 April 2019  on unfair trading 
practices in business-to-business relationships in the agricultural and food supply chain, OJ L 111, 24.05.2019, 
p. 59-72.    

47 SWD(2024)106 final with overview of Member States’ transposition choices and enforcement activities. 
48 Regulation (EU) No 1308/2013. 
49 Set up under the CSP Regulation; see: https://eu-cap-network.ec.europa.eu/about/eu-cap-network_en  

20 

 
 
 
information  about  agriculture  and  rural  policy.  One  of  the  thematic  groups  within  the  CAP 
Network focuses on designing green strategies under the CAP Plans. 

These exchanges serve to identify and share, for example, which elements of the CAP Plans’ 
green  architecture  were  used  and  how  well  they  work  together.  This  includes  positive 
experiences and challenges, and the key factors that influenced the design of CAP Plans to 
address environmental and climate needs. They also serve to explore the different approaches 
taken with the CAP Plans and how they interact with national funding opportunities.  

Support for advisory services  

Knowledge and innovation brought to the field by advisors (for example in the context of the 
EU Soil Mission50) play a crucial role in helping farmers, foresters and rural communities make 
the  necessary  transition  to  sustainability.  If  advisory  services  are  poorly  organised, 
insufficiently targeted, or overly bureaucratic, they may present more challenges than solutions. 
These  circumstances  may  contribute  to  the  low  uptake  by  farmers  of  measures  to  improve 
knowledge  and  may  have  an  impact,  for  example,  on  the  rate  of  adoption  of  sustainable 
practices, whether or not supported under the CAP. It is therefore essential that advisory services 
are impartial,  competent,  and able to  provide  well-tailored advice, i.e.  they should be  easily 
accessible,  respond  to  the  specific  needs  of  farmers  and  not  impose  another  administrative 
burden on them.  

On 12 April 2024, the Commission sent a note to Member States proposing actions that would 
encourage  them  to  strengthen  the  role  of  advisory  services  to  include  and  support  all 
impartial  advisors,  both  public  and  private,  and  integrate  them  into  their  Agricultural 
Knowledge  and  Innovation  System  (AKIS). A  national  public  database  of  all  impartial 
advisors  can  provide  a  transparent  overview  on  which  advisors  are  available,  on  their 
experience and education, and their expertise. Such  a database gives farmers the freedom to 
choose their advisor based on objective information and ensures the highest possible impact of 
the  CAP  funding  invested  in  providing  advice.  This  approach  will  help  single  out  the  best 
impartial advisors, who are most appreciated by farmers. 

5.5 Elements outside the CAP  

Use  of  remote  sensing  services  according  to  the  proposed  Soil  Monitoring  and  Forest 
Monitoring Laws 
In this proposed legislation51 (the Soil Monitoring Law and the Forest Monitoring Law) the 
Commission  intends  to  develop  and  to  strengthen  remote  sensing  services  in  the  context  of 
Copernicus. These  services  could  help  simplify  the  monitoring  of  some  of  the  relevant  soil 
descriptors  and  make  it  easier  to  assess  soil  health.  Earth  observation  can  also  improve  the 
efficiency and timeliness of forest monitoring, especially with regard to the health and condition 
of forests and can help Member States to design and implement measures more efficiently and 
effectively.  

50 Under Horizon Europe, the EU Mission ‘A Soil Deal for Europe’ is creating a network of 100 Living Labs and 
Lighthouses, where land managers will test innovative soil health solutions on the ground, to lead the transition 
towards healthy soils by 2030. The results of the Mission’s Living Labs are expected to be replicated and scaled 
up by around 1 000 CAP Network Operational Groups (with EUR 350 million of funding) to work on improving 
soil  quality,  bringing  together  farmers,  scientists  and  industry  at  the  local  level  to  find  solutions  to  soil 
challenges, such as fertility, water management or pest control. 

51 Proposal for a Directive of the European Parliament and of the Council on Soil Monitoring and Resilience (Soil 
Monitoring Law) COM(2023)416 final; Proposal for a Regulation of the European Parliament and of the Council 
on a monitoring framework for resilient European forests COM(2023)728 final.  

21 

 
 
 
At the time of writing this document, the proposed Forest Monitoring Law was being discussed 
by the Council. The proposal aims to: (i) ensure consistent high-quality monitoring that will 
make  it  possible  to  track  progress  towards  achieving  EU  policy  objectives  and  targets;  (ii) 
improve  risk  assessment  and  preparedness;  (iii)  support  evidence-based  decision-making  by 
land managers and public authorities; (iv) promote research and innovation. 

The trilogues for the Soil Monitoring Law started on 22 October 2024. The proposal aims to 
put in place a solid and consistent soil monitoring framework for all soils across the EU and to 
continuously improve soil health with a view to achieving healthy soils by 2050. The proposed 
Directive therefore lays down measures on monitoring and  assessing soil health, sustainable 
soil management and contaminated sites. The Commission is currently making an inventory of 
the policy needs for the next Copernicus programme to prepare the next multiannual financial 
framework (MFF).  

Exemption of plant protection products containing only biological active substances from 
the obligation to keep records 

In  the  context  of  the  study  announced  in  Action  1  of  the  Communication  on  Boosting 
Biotechnology and Biomanufacturing in the EU52, which is due to be finalised in mid-2025, the 
Commission  will  examine  whether  to  exempt  plant  protection  products  containing  only 
biological  active  substances  from  the  obligation  to  keep  records.  This  exemption  to  the 
obligation under Article 67(1) of the Regulation on placing plant protection products (PPPs) on 
the market53, is aimed at reducing the administrative burden on farmers who use such products.  

Eliminate the requirement that farmers must submit individual applications for aerial 
spraying of plant protection products once relevant conditions are met54 

 The Commission is considering this proposal. 

Eliminate  the  requirement  for  farmers  to  keep  records  of  treatment  of  animals  with 
medicinal  products  under  the  Directive  on  the  protection  of  animals  kept  for  farming 
purposes55  

The Commission is considering this proposal. 

Evaluation of the Nitrates Directive 
An  evaluation  of  the  Nitrates  Directive56  (relevant  in  relation  to  the  SMR  2  conditionality 
requirement57)  is  ongoing  and  included  a  public  consultation.  The  Commission  invited 
stakeholders to participate in this consultation, also to express their views on the administrative 
burden under this piece of legislation. The consultation closed on 8 March 2024. The views 
expressed will be taken into account in the ongoing evaluation.   

In response to requests from Member States and farmers’ organisations, the Commission also 
presented  on  19 April  2024,  for  public  feedback58,  a  draft  amendment  to Annex  III  of  the 

52 COM(2024)137 final 
53 Article 67(1) of Regulation (EC) No 1107/2009. 
54 Article 9(4) of Directive 2009/128/EC 
55 Directive 98/58/EC. 
56 Directive 91/676/EEC. 
57  Statutory  Management  Requirement  (SMR)  2  (in  Annex  III  to  CSP  Regulation)  under  the  conditionality, 
subjecting  certain  CAP  payments  to  the  respect  by  beneficiaries  of  specific  requirements  of  the  Nitrates 
Directive. 

58 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14242-Nitrates-updated-rules-on-the-

use-of-certain-fertilising-materials-from-livestock-manure-RENURE-_en  

22 

 
 
 
Nitrates Directive, which will allow Member States to authorise the use of RENURE fertilisers 
(i.e.  fertilisers  derived  from  manure)  by  farmers  above  the  limit  for  manure  application  in 
Nitrates Vulnerable Zones, thereby contributing to the replacement of chemical fertilisers. This 
draft amendment is aimed to be an interim solution to address the immediate needs of farmers 
while also ensuring appropriate safeguards to comply with environmental protection objectives, 
particularly  the  protection  of  waters  against  pollution  caused  by  nitrates  from  agricultural 
sources.  

Actions in relation to the EU Deforestation Regulation  
The EU Deforestation Regulation59 lays down rules to ensure that certain commodities (cattle, 
cocoa,  coffee,  oil  palm,  rubber,  soya  and  wood)  and  relevant  products  are  placed  or  made 
available  on  the  Union  market  or  exported,  only  if  they  are  deforestation-free,  have  been 
produced in accordance with the relevant legislation of the country of production and covered 
by a due diligence statement.  

To address concerns raised in relation to the Regulation, the Commission put forward a set of 
measures in  its package  of 2 October 202460. This  includes a proposal  for  an additional  12-
month  phasing-in  period,  which  –  upon  agreement  of  co-legislators  –  will  shift  the  date  of 
applicability by 12 months, to allow operators, traders and competent authorities to be better 
prepared  and  to  fully  establish  the  necessary  due  diligence  systems.  In  addition,  the 
Commission published a Guidance Document and Frequently Asked Questions (FAQs) which 
address and clarify many issues raised by farmers and forest owners (see also Annex 2, page 
109).  

6.  MAIN IMPACTS OF THE SIMPLIFICATION MEASURES 

Delivering  on  its  commitment  to  ease  the  administrative  burden  on  EU  farmers,  the 
Commission listened attentively to the concerns expressed by farmers, their organisations and 
Member States, and acted on them by delivering concrete measures under the simplification 
package. They were developed based on suggestions made by and in close cooperation with 
national administrations and farmers’ representatives. As such, this exercise should contribute 
to building trust between the different actors and levels of governance, which is an essential 
factor  in  better  policy  delivery.  The  impact  analysis  of  these  measures  is  summarised  
in Annex 3. 

6.1 Impacts on the administrative burden for beneficiaries and national administrations 

Beneficiaries/farmers 

The simplification package is likely to reduce the time that CAP beneficiaries need to dedicate 
to applications and checks. For some of the measures, quantitative estimates of cost reductions 
could be made. 

Processes can be simplified through the digitalisation of the CAP application procedures (e.g. 
by using geotagged photos), and the automatic processing of feedback received by farmers from 
the authorities (early warning notifications under the AMS). The first year of implementation 
has  showed  that  these  solutions  have  often  not  been  taken  up.  The  actions  taken  by  the 
Commission (e.g. measures A.4 and A.6 in Annex 1) aim to improve the workability of these 

59 Regulation (EU) 2023/1115 
60 https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5009 

23 

 
 
 
solutions, 
The impact of these actions is difficult to quantify. 

thereby  reducing 

the  burden  on  farmers 

linked 

to  on-site 

inspections.  

The Commission’s clarification of the concept of force majeure (measure A.5 in Annex 1) helps 
reduce the administrative burden for farmers as it eliminates the need to introduce individual 
requests, including gathering the evidence and providing it to the authorities. Quantification of 
the resulting benefits is not possible as it depends on the occurrence of unpredictable events. 

The simplification package also streamlines the approach to controls (measures A.3, A.6, B.2 
in Annex 1), resulting in fewer on-site visits by the administration, thereby leaving farmers 
more time to dedicate to their core work. 

In  particular,  the  revision  of  the  IACS  quality  assessment  methodology  (measure  A.3  in 
Annex 1), should  significantly reduce  the number of  visited farms  in  the  quality  assessment 
sample. It is estimated that the change will reduce the number of visited farms by 50% or more 
compared to 2023. Assuming a reduction of around 174 000 field visits, this translates to an 
annual reduction of administrative costs equivalent to EUR 61.8 million for farmers, using 
average EU values for labour costs. The Commission’s clarifications on the usage of geotagged 
photos should further reduce the number of on-farm visits and the associated costs.  

Farms under 10 hectares of agricultural area represent 65% of CAP beneficiaries. These farms 
operate on around 9.6% of the EU’s agricultural area and receive around 11% of the EU direct 
payments  (Figure  2).  Performing  conditionality  controls  on  these  farms  was  thus  deemed 
disproportionate.  Their  removal  (measure  B.2  in  Annex  1)  is  estimated  to  result  in 
approximately 37 600 fewer controls every year. This translates into an annual reduction in 
the administrative burden of EUR 6.7 million for farmers, based on the average EU values 
for  labour  costs. The  scope  of  this  modification  and,  therefore,  its  economic  impact,  differs 
according to the structure of each Member State’s agricultural sector.  

It is more difficult to assess time and cost savings for several other actions and depends on how 
Member States take up the opportunities provided.  

Figure 2 Farms below 10 ha at EU level 

Farm size 
class 

Number of 
beneficiaries 

Area [ha] 

(million) 

Direct 
payments 
[EUR] 

% 
Beneficiaries 

% Area 

% Direct 
payments 

 All farms 

<= 10ha 

5.8 

3.8 

140.7 m 

13.6 m 

37.1 bn 

4.1 bn 

100.0% 

100.0% 

65.3% 

9.6% 

100.0% 

11.1% 

Source: DG AGRI, CATS database, data for 27 Member States (2022)  

In the absence of data on the number of farmers that benefit from the 2023-2027 CAP and who, 
at the same time, continue to benefit from rural development support under the 2014-2022 CAP, 
it  is  not  possible  to  estimate  the  costs  saved  by  removing  the  ‘cross-compliance’  controls 
(measure B.4 in Annex 1) in such cases. 

The  reduction  of  hassle  costs  and  uncertainty  for  farmers  is  another  important  economic 
effect of the changes brought by the simplification package. Actions which contribute to this 
include improvements to the early warning systems, the right of error (measure A.6 in Annex 1), 
in  Annex  1).  
and  clarification  of 
These  actions  will  help  prevent  a  reduction  or  withdrawal  of  CAP  support  for  farmers, 
which  they  have  already  factored  in  their  farm  management  decision-making  process  as  a 

force  majeure  (measure  A.5 

the  concept  of 

24 

 
 
source of additional income or to compensate for efforts made for specific practices, thereby 
preventing possible negative economic impacts if support is foregone. Moreover, these actions 
also facilitate the handling of aid applications by administrations, thereby reducing the waiting 
time  for  the  response. The  reduction  of  uncertainty  will  also  have  a  positive  impact  on  the 
mental well-being of beneficiaries, by reducing stress (see Section 6.4 on social impacts).   

National administrations 

The measures taken will also streamline the processes for national administrations.  

In  particular,  the  simplification  package  will  reduce  enforcement  costs  linked  to  on-site 
controls. The revision of the IACS quality assessment methodology (measure A3 in Annex 1) 
and  the  removal  of  controls  on  conditionality  for  farms  under  10  hectares  (measure  B.2  in 
Annex1) are estimated to result in annual cost savings for national administrations of EUR 82.4 
million and EUR 13.4 million respectively, using average EU values for labour costs. Further 
actions contribute to the simplification of controls, such as digitalisation of procedures and the 
removal of the remaining ‘cross-compliance’ controls (measure B.4 in Annex 1), though these 
benefits could not be quantified. 

Automated  IT  processes  to  inform  farmers  of  potential  errors  in  applications  will  reduce 
administrative  checks  by  national  administrations.  Clarification  of  the  concept  of  force 
majeure (measure A.5 in Annex 1) eliminates the need for case-by-case assessments by national 
administrations, where the relevant elements proving the adverse event in an identifiable area 
have  been  established. This  facilitates  a  Member  State’s  response  to  such  disturbances. The 
streamlined  process  to  approve  CSP  amendments  (measure  A.9  and  B.5  in  Annex  1)  and 
simplified descriptions of interventions will also contribute to lower administrative costs for 
national administrations.    

6.2 Other economic impacts  

The package of measures reduces not only costs and risks due to changes in the administrative 
burden, but also other economic aspects. This is specifically the case for changes to the CAP 
Plans’ green architecture. Due to difficulties in quantifying the impacts of the changes made to 
the CAP Plans’ green architecture in many cases, a qualitative assessment is provided.  

Changes  to  the  rules  under  GAEC  1  (permanent  grasslands  –  maintenance  of  a  ratio, 
measure A.1 in Annex 1) gave Member States the possibility to  better integrate structural 
changes  with  the  needs  of  farmers  to  manage  their  farms  in  response  to  market 
developments. It will be possible for national administrations to react to the effects of such 
changes in a tailor-made way, while the objective of the standard (climate change mitigation) 
is respected. More precisely:  

•  When market developments force farmers to abandon or reduce livestock production 
and consequently – because the need to feed livestock has been reduced or eliminated – 
shift production away from grassland and herbaceous fodder towards arable crops, the 
provisions  will  allow  Member  States  to  adjust  the  2018  reference  ratio.  This  should 
prevent  farmers  from  being  required  to  re-establish  permanent  grasslands  without 
having  livestock,  and  potentially  without  an  outlet  for  the  fodder  produced,  if  the 
livestock  sector  in  the  region  concerned  has  shrunk.  In  such  cases,  the  obligation  to 
(re)establish  permanent  grassland  could  prevent  farmers  from  maintaining  an 
economically viable activity.  

25 

 
 
•  Member States are also allowed to consider further factors. They can take into account 
various situations where a reduction in the ratio of permanent grassland does not result 
from farmers converting permanent grassland to other agricultural uses, and where it 
would therefore be disproportionate to ask farmers to re-establish areas of permanent 
grassland. Such situations include, for instance, the case where the change in the ratio 
results  from  an  increase  in  the  total  agricultural  area.  Member  States  also  have,  for 
instance, the possibility to take into account the existence of non-declared permanent 
grassland. 

The adjustments to GAEC 6 (soil cover, measure B.1 in Annex 1) provide greater flexibility to 
Member States, in particular to define the sensitive period during which soils should be covered. 
This can give farmers greater flexibility in organising soil preparation and can reduce the 
constraints and the related financial risks. How Member States will use this adjustment remains 
largely unknown at this stage, although the Commission has already received several requests 
to  shorten  the  sensitive  periods.  At  the  same  time,  it  remains  essential  that  the  adjusted 
requirements in the CAP Plans keep contributing to the main objective of the standard as poor 
soil quality can seriously affect agricultural production, including resilience and productivity, 
resulting in economic losses. 

The existing flexibilities under GAEC 7 ensure a system of crop rotation on all parcels of land 
over  several  years,  which  is  suitable  for  all  the  main  types  of  farming,  and  which  avoids 
unnecessary  rigidities.  The  option  of  a  yearly  diversification  of  crops  (measure  B.1  in 
Annex 1) provides further flexibility for managing parcel allocation. This can be useful for 
some farming systems, and the actual situation on farms, by reducing uncertainty costs while 
still serving the objective of  preserving soil potential,  and thus  also the productivity of the 
land.  

It  is  difficult  to  make  an  assessment  of  the  impact  (both  economic  and  environmental,  see 
Section 6.3) of removing the GAEC 8 first requirement (the share of non-productive areas 
and  features,  measure  B.1  in  Annex  1)  due  to:  (i)  the  lack  of  reference  data  on  the 
implementation of that requirement; (ii) the lack of information on the extent to which farmers 
would  declare  existing  landscape  features  or  fallow  land  to  fulfil  the  requirement;  
(iii) the future coverage (Member States are not obliged to have interventions with the same 
scope as the deleted GAEC 8 requirement), uptake and impact of the eco-scheme to be created 
by Member States to replace this GAEC 8 requirement (see also Section 6.3). 

Notwithstanding  these  constraints,  the  estimate  made  by  the  Commission’s  Joint  Research 
Centre through the ‘Individual Farm Model for Common Agricultural Policy Analysis (IFM-
CAP)61 and based on data from the Farm Accountancy Data Network (FADN), provides some 
indications of additional income for farmers as a result of this change. The approach taken in 
this modelling exercise is explained in Annex 4. 

According to these estimates, lifting this GAEC 8 requirement will impact roughly 1.1 million 
farms, covering approximately 76 million hectares of arable land, by potentially freeing for 
production close to 2.1 million hectares of ‘GAEC 8 non-productive land’. That is the area 
which, in the absence of the adjustments, would have been dedicated to additional fallow-land 
or landscape features such as woody elements or grass strips. At the EU level, the economic 
impact  measured  as  the  annual  change  in  the  gross  margin  of  arable  crops  (additional 

61 A model description as well as technical details of the model can be found at: 

https://midas.jrc.cec.eu.int/discovery/midas/explore/models/model-ifm-cap/ and 
https://publications.jrc.ec.europa.eu/repository/handle/JRC127014  

26 

 
 
 
income/avoided income loss) is estimated to be around EUR 930 million. This corresponds 
to a 1.5% increase in gross margin for the impacted farms, though this may differ at more 
disaggregated  level,  such  as  according  to  the  economic  size  of  the  farms  or  the  type  of 
production.  

Another insight comes from the uptake of the 2023 derogations from this GAEC 8 requirement, 
with significant variations across Member States in terms of land taken up for production. This 
uptake resulted in the cultivation of cereals and, to a lesser extent, dry pulses and leguminous 
crops,  rapeseed,  sunflower  and  potatoes,  generating  additional  income  opportunities. 
Differences in the quality of fallow land to produce crops, in the size and location of the fallow 
land, and in the existence and attractiveness of voluntary measures influenced land use in that 
year. This provides a good indication for what is likely to occur.  

At the same time, the economic benefits of additional landscape features and of fallow land 
on arable farms should not be neglected, given their benefits for the farms’ resilience, the overall 
stability of crop production and agricultural productivity in the medium and long term through 
eco-system benefits in relation to water retention and quality, pest control and the prevention 
of soil erosion. 

The  IFM-CAP  calculations  do  not  consider  the  introduction  of  eco-schemes  for  the 
maintenance of non-productive areas and for the establishment of new landscape features that 
Member  States  are  required  to  set  up  in  compensation  for  removing  the  GAEC  8  first 
requirement. As these eco-schemes are voluntary for farmers, it can be assumed that farmers 
will engage only where the compensation offered will surpass their extra costs. This could be 
particularly attractive for farmers who already have fallow land or marginal and low productive 
arable land, where the commitment to leave it non-productive implies a limited opportunity cost 
and less attractive for more intensive farms. Also, farmers with more productive arable land 
could enter a voluntary commitment, given the financial compensation and the advantages that 
the presence of non-productive areas create for the holding’s long-term productivity.  

Leeway  granted  to  Member  States  to  set  out  in  their  CAP  Plans  targeted  and  duly  justified 
exemptions  from  the  requirements  under  GAECs  5,  6,  7  and  9,  or  to  grant  time-limited 
derogations to help tackle the effects of unexpected weather events (measure B.1 in Annex 1),  
can reduce specific structural or meteorological obstacles for farmers. While the scope of 
both  facilities  should  be  limited  (in  terms  of  areas  and  farmers),  they  might  have  important 
positive economic effects or limit  possible negative economic  consequences  for the  farmers 
concerned. In the case of GAEC 7, an example could be parcels used to produce certified seeds. 
Imposing  crop  rotation  would  be  disproportionate  as  it  would  make  it  significantly  more 
difficult to fulfil the specific requirements for producing certified seeds, with an impact on the 
potential revenue related to such production.  

6.3 Environmental impacts 

Administrative measures such as improved monitoring, the uptake of geotagging and early 
warning, the better design of CAP interventions and improved access to advice (measures A.4, 
A.6, A.7 and A.8 in Annex 1) help farmers to adjust farm management practices in a timely 
manner  where  needed,  thus  ensuring  that  there  are  benefits  for  the  environment  and 
climate. This contributes not only to better environmental outcomes for mandatory practices 
but also makes it more likely that farmers make these voluntary commitments in the future. 
For  this  reason,  the  potential  environmental  impact  of  these  measures  is  considered  to  be 
generally positive. 

27 

 
 
Assessing the impact of lifting the conditionality controls and penalties on smaller farms 
(measure B.2 in Annex 1) needs to be nuanced and cannot be properly assessed at this stage due 
to its novelty. First, these farms are not exempt from conditionality requirements under the CAP, 
nor under the relevant EU law in case of the SMRs62. Secondly, voluntary commitments have 
conditionality as a baseline and the practices to which farmers subscribe should go beyond the 
conditionality.  Therefore,  small  farms  participating  in  voluntary  CAP  interventions,  for 
example  eco-schemes,  will  inherently  have  to  fulfil  the  related  conditionality  requirements, 
particularly GAEC standard(s) that are part of the baseline for these interventions. Thirdly, due 
to the relatively small agricultural surface managed by small farmers (accounting for around 
9.6% of the EU’s total agricultural area), any potential non-compliance should not significantly 
hamper the objectives of these GAEC standards. The impact differs between Member States 
because of the significant differences in the share of smaller farms.  

Changes  to  the  delegated  legislation  on  the  ratio  of  permanent  grassland  under  GAEC  1 
(measure A.1  in Annex  1)  are  not  expected  to  affect  its  main  objective  to  be  a  ‘general 
safeguard against conversion to other agricultural uses to preserve carbon stock’ with only a 
modest impact on the entirety of the carbon stock. The flexibility granted to Member States will 
not incentivise the conversion of permanent grassland but will make it possible to take into 
account significant structural developments in a strictly defined way, and gives Member States 
the option to consider a more nuanced implementation of the requirement.   

The modifications of the CSP Regulation provide that exemptions to GAEC 5 (tillage), GAEC 
6  (soil  cover),  GAEC  7  (crop  rotation/crop  diversification)  and  GAEC  9  (environmentally 
sensitive  permanent  grasslands)  (measure  B.1  in Annex  1)  shall  be  targeted  in  a  way  that 
ensures that the exemption will not significantly hamper the main objectives of these GAEC 
standards, and hence they should not significantly affect the environmental impacts of the 
CAP plans.  

By making it possible to take greater account of the diverse and sometimes complex nature 
of  farming  and  of  factors  affecting  the  impact  of  certain  practices  on  the  environment  
(e.g. the characteristics of specific types of production, farming systems, types of soil, crops 
and/or Member States’ pedoclimatic conditions), these requirements can be designed to limit 
the potential environmental drawbacks of otherwise good practices. For instance, in the case of 
GAEC 6, the characteristics of heavy clay soil can be such that the benefits of ensuring a full 
minimum soil cover over winter need to be balanced against the risk of compaction posed by 
preparing the soil for sowing in early spring. Similarly, the use of mechanical weeding under 
organic farming may make it necessary to prepare the soil at an early stage. When considering 
such exemptions it is, however, important to also keep in mind the long-term impact of certain 
practices  on  the  objectives  of  the  GAEC  standard  and  give  value  to  the  range  of  different 
farming practices that exist. 

The main requirement for farmers set out across all CAP Plans under GAEC 9 (environmentally 
sensitive  permanent  grasslands  in  Natura  2000  areas)  entails  a  ban  on  the  conversion  and 
ploughing up of these grasslands. This is a continuation of the greening rules  that applied during 
the pre-2023 CAP period. The amendments brought by the Commission’s proposal of 15 March 

62 These exemptions only concern controls and penalties of conditionality under the CAP and are without prejudice 
to any controls or penalties outside the system of conditionality. A limited number of obligations in the scope of 
conditionality rules are based on existing EU directives and regulations on climate and the environment, public 
and plant health, and animal welfare (the sectoral legislation). The requirements laid down in those  EU legal 
acts, including provisions on controls and penalties, continue to be applicable outside the CAP framework. 
28 

 
 
 
2024 to allow targeted exemptions ensure, in particular, that where the grass cover has been 
destroyed (e.g. due to damage made by wild animals or invasive species), the necessary tillage 
can be carried out to restore the grassland. This reflects both agronomic and biodiversity 
considerations for the renewal and regeneration of such grasslands, though the actual impact 
of this flexibility will depend on Member States’ implementation choices. If applied properly 
this flexibility should not, in principle, substantially affect the contribution of this requirement 
to the standard’s biodiversity objective. 

The possibility to grant temporary derogations (measure B.1 in Annex 1) will enable Member 
States to address the consequences of increasingly unpredictable weather events, such as the 
drought episodes and rainfalls of autumn 2023. As this concerns situations where farmers are 
prevented  from  respecting  GAEC  requirements,  such  temporary  derogations  should  have  a 
neutral  effect  on  the  environment.  In  some  cases,  the  derogations  should  also  serve  the 
purpose of avoiding counterproductive  consequences for farmers aiming to satisfy GAEC 
requirements against what is agronomically practicable.  

It follows that, overall, these amendments to the CAP framework (targeted exemptions and 
temporary derogations)  are expected to  have a limited environmental impact, if applied 
properly, since they are tools to address specific situations and problems without substantially 
changing basic practices.  

As regards GAEC 6 (minimum soil cover, measure B.1 in Annex 1), while in many cases the 
main objective of this GAEC (the protection of soil against erosion) is further supported by 
voluntary commitments relating to e.g. green cover, catch crops and enhanced crop rotation or 
diversification, the overall impact will depend on the scope and uptake of these commitments.  

Crop  diversification,  as  an  alternative  to  crop  rotation  under  GAEC  7  (measure  B.1  in 
Annex 1) provides  farmers with  an extra choice  but  maintains  its role  in helping  to make 
farming systems more resilient. With crop rotation, farmers change the crops grown on each 
parcel  from  one  or  more  year(s)  to  another.  This  limits  the  depletion  of  soil  nutrients  and  
the spread of pathogens. Despite the requirement to have at least two or three different crops on 
a farm in any given year, crop diversification might not guarantee a similar change in crops on 
land over time. While this might not bring the full environmental benefits of crop rotation, one 
of the purposes of crop diversification is to prevent a generalisation of monoculture which 
could  be  happening  in  some  arable  areas  due  to  structural  changes.  It  also  indirectly 
encourages  rotation,  as  once  farmers  are  obliged  to  have  different  crops,  it  makes  sense 
agronomically to alternate them in the fields in the following year. 

The environmental impacts of the change to GAEC 7 will depend on the level of diversity that 
will be required, especially the number and type of crops (e.g. leguminous crops), the share of 
different  crops  as  well  as  the  crop  definition  for  this  purpose,  and  then  the  extent  to  which 
farmers will choose this option. Allowing a high proportion of the land to be allocated for the 
main  crop  in  diversification  may  imply  a  more  static  situation  with  fewer  environmental 
benefits.  To  prevent  this,  the  Commission  proposal  incorporates  minimum  requirements 
identical  to  the  ones  set  under  the  greening  scheme  in  the  pre-2023  CAP  (based  on  the 
requirement to have three crops, with a maximum of 75% coverage for the main crop).  

The greening scheme’s experience of the crop diversification requirement showed that while 
it had a limited influence over the cropping patterns at macro level it increased diversification 
of  certain  farms.  This  is  particularly  true  in  areas  with  high  levels  of  monocropping,  by 

29 

 
 
replacing maize or other cereals with crops that provide better soil cover (which improves soil 
structure) like legumes or fallow land. This requirement also encouraged  rotation63. 

As the most plausible scenario, a return to  practice of diversification of crops could occur 
in most Member States, but farmers will continue to have the choice to fulfil the GAEC standard 
through rotation. Also in this case, the contribution of the CAP Plans will heavily depend on 
their articulation with voluntary commitments that go beyond GAEC 7. 

The  fundamental  change  in  the  simplification  package  concerns  GAEC  8  (measure  B.1  in 
Annex 1). The core new and strengthened requirement, compared to the pre-2023 CAP, was the 
share of arable land to be devoted to non-productive areas and elements at farm level (4%, and 
in some cases 3%). The assessment of the environmental impact of removing this obligation is 
constrained in particular by the lack of experience of full implementation (see also the previous 
section).  Its  replacement  with  a  compulsory  eco-scheme  to  improve  on-farm  biodiversity 
through incentives can only be assessed when the design and the level of uptake by farmers of 
these  new  eco-schemes  becomes  known.  Furthermore,  many  CAP  Plans  include  voluntary 
interventions that build on the first requirement of GAEC 8, in term of quality and/or quantity, 
and those might also be revised. With the removal of the obligation, it is likely that the total 
size  of  non-productive  areas  and  features  on  arable  land  will  decrease  due  to  economic 
pressures. 

The best available reference figures to support an assessment come from the FADN records 
for  fallow  land  (see  also  Section  6.2  above),  the  LUCAS  (land  use/land  cover)  survey  for 
landscape features, and, as regards the areas covered by the first requirement of GAEC 8, from 
implementation of the obligation in the pre-2023 CAP to create Ecological Focus Areas (EFAs).  
However,  productive  areas  such  as  catch  crops,  nitrogen-fixing  crops  and  short-rotation 
coppices were also permitted under this EFA obligation.  

At macro level (EU, Member States), the deletion of the first requirement of GAEC 8 on non-
productive elements (areas and features) is not expected to entail an equivalent reduction in 
the  arable  land  devoted  to  non-productive  areas  and  features.  GAEC  8  maintains  a 
requirement to protect existing landscape features, and a certain level of fallow land will still 
be kept for agronomic purposes (‘voluntary fallow’).  

Furthermore, the 2022 LUCAS survey determined that woody, grassy, wet and stony elements 
comprised  an  average  of  4.9  %  of  EU  arable  land,  ranging  from  3%  to  9%  at  the  level  of 
Member States. At the level of EU agricultural land this share is 5.6% (Figure 3). However, not 
all of these elements may have been within the scope of the GAEC 8 retention requirement and, 
therefore, were not declared under the EFA. The estimates based on the FADN data indicate 
that  at  least  1.2  million  hectares  under  the  CAP  would  remain  fallow  in  the  absence  of  the 
GAEC 8 requirement. 

63 Commission Staff Working Document. Evaluation. Impact of the CAP on biodiversity, soil and water (natural 

resources), SWD/2021/0424 final. 

30 

 
 
 
 
 
Figure  3  Share  of  landscape  features  on  agricultural  land  at  NUTS  2  level  (CAP  impact 
indicator I.21) 

Source: JRC, more at : https://publications.jrc.ec.europa.eu/repository/handle/JRC136069 

There are certainly significant differences between farming systems and farm locations.  There 
is an unequal distribution of fallow land and landscape features among farms. As a consequence, 
it is expected that the impact of the removal of the GAEC 8 first requirement on biodiversity 
will  be  seen  in  regions  with  few  landscape  features  and  highly  productive  arable  land, 
which  are  then  also  less  likely  to  commit  to  voluntary  measures.  The  literature  review  has 
shown the benefits of a wide distribution of non-productive elements across holding parcels as 
regards ecosystem services. These benefits include: (i) the  limiting of erosion thanks to the 
effect of hedgerows on improved soil quality; (ii) the effect of windbreaks on microclimates; 
(iii)  a  reduction  in  diffuse  pollution  by  nitrates  and  phosphates;  (iv)  a  reduced  use  of  plant 
protection products; (v) increased pollination and (vi) greater control of crop pests. However, 
these benefits  may not materialise  for the  farming systems  characterised by few landscape 
features and highly productive arable land. 

While GAEC 8 aims to improve biodiversity on farms, there are other environmental effects 
linked to non-productive areas given that, in general, they are free from fertilisers and plant 
protection products. Based on the estimates on the economic impacts calculated using the IFM-
CAP  model  (Annex  4),  the  quantity  of  nitrogen  mineral-fertiliser  used  in  relation  to  the 
deletion of the GAEC 8 first requirement could increase by around 9.5 million tonnes (+2.1%) 
for  the  impacted  farms.  The  increase  in  annual  greenhouse  gas  emissions  due  to  mineral 
fertilisation is estimated to be in the range of 900 kt CO₂ equivalent (+0.21%) for the impacted 
farms  (compared  to  the  situation  with  GAEC  8,  first  requirement).  These  figures  do  not 
represent actual increases in most Member States, as the GAEC 8  first requirement was not 
applied  in  many  countries  in  2023.  So,  these  figures  rather  represent  the  absence  of  a 
decrease that could have happened due to the GAEC 8 first requirement. The figures cover 
the estimated use of mineral fertilisers on the 2.1 million hectares of arable land concerned. 
Other environmental impacts, in particular on biodiversity, could not be quantitatively assessed 
at the time of writing by using IFM-CAP.  

31 

 
 
 
 6.4 Social impacts  

Farmer  communities  tend  to  perceive  the  control  and  penalty  systems  negatively,  as  being 
disproportionately focused on and penalising minor or incomprehensible non-compliances. 

With better use of the tools that Member States have at their disposal during the 2023-2027 
CAP and with adjustments brought by the simplification package, farmers’ applications for CAP 
support can be completed more easily and then, if necessary, corrected in time so that eventual 
penalties may be avoided (measures A.6 and A.7 in Annex 1). There should also be fewer on-
site checks and a more straightforward treatment of force majeure cases (measures A.3, A.5, 
A.6, B.2 and B.4 in Annex 1). These changes should not only simplify farmers' administrative 
tasks, but also reduce stress factors. Similarly, the increased flexibility and removal of certain 
restrictions on farm management (measure B.1 in Annex 1), should simplify their daily work 
and  reduce  the  incomprehension  and  frustration  linked  to  what  farmers  perceive  as 
interference in farm management in opposition to the agronomic reality, and for which they see 
no direct economic benefits.  

The advisory services have an essential role, particularly for small and medium-sized farms, 
when  introducing  new  technologies  and  innovative  solutions.  Due  to  limited  resources  and 
technical  knowledge,  those  farmers  often  have  more  difficulty  in  implementing  modern 
agricultural practices and making their farms more competitive. Improving the availability of 
independent  and  targeted  quality  advice (measure A.8 in Annex  1)  will have  significant  and 
positive effects on the number of skilled people employed and on the management of farms, 
considering their specific needs, including as regards more sustainable farming, thus promoting 
the CAP’s environmental and climate objectives. 

6.5 Impacts relating to the performance, monitoring and evaluation framework 

The orientation on results as well as the increased flexibility in the new delivery model of the 
CAP,  based  on  CAP  plans,  relies  upon  a  robust  performance,  monitoring  and  evaluation 
framework  (PMEF).  The  simplification  changes  made  to  existing  legislation,  and  other 
accompanying actions, therefore also require modifications of certain elements of the PMEF 
set out in the CAP Plans: indicators, unit amounts, financial allocation and reporting. 

When  designing  the  PMEF,  improved  conditionality  (including  the  first  requirement  of 
GAEC 8) has been treated as the baseline, i.e. the level of environmental improvements to be 
reached by all EU farmers receiving CAP support. Thus, area-based result indicators relate only 
to the voluntary commitments that go beyond these mandatory practices. Removing the GAEC 
8  first  requirement  and  replacing  it  with  new  voluntary  commitments  (measure  B.1  in  
Annex 1) implies that the values that result indicators should reach for the share of areas under 
these  commitments  (such  as  R.31  Preserving  habitats  and  species  and  R.34  Preserving 
landscape features) would normally be higher (since areas under the GAEC 8 first requirement 
were  not  considered  in  these  indicators),  though  this  does  not  necessarily  lead  to  greater 
impacts.  

Several  interventions  (mainly eco-schemes and agri-environment-climate commitments)  that 
build on the GAEC 8 first requirement64 are also impacted. When designing these interventions, 
Member States could not take into account the hectares needed to comply with the GAEC 8 
first  requirement.  Following  the  removal  of  this  requirement,  Member  States  will  have  
the  possibility  to  take  these  hectares  into  account  in  the  payments  of  the  interventions  

64 According to data extracted the 30 April 2024 from the Catalogue of CAP interventions on the agri food data 

portal 121 interventions across all 28 CSP. 

32 

 
 
 
to cover the related costs. This could lead to a higher uptake and, therefore, to higher outputs 
and higher values under the relevant result indicators. 

Finally, to incorporate new eco-schemes in their CAP Plans or to increase the unit amounts of 
eco-schemes or other interventions, Member States will need to revise their CAP Plans, which 
may  require  them  to  reassess  priorities  and  reallocate  the  current  financial  allocations, 
leading  potentially  to  a  reduction  in  the  planned  outputs  for  other  interventions  and  
in the relevant result indicators.  

All these changes will require CAP Plan amendments before the start of the 2025 claim year. 

Monitoring 

The  need  to  collect  information  on  the  temporary  derogations  from  GAECs  and  the  eco-
schemes introduced in connection with deleting the GAEC 8 first requirement (measure B.1 in 
Annex  1)  required  changes  in  the  related  secondary  EU  legislation65  as  regards  the 
evaluation  of  the  CAP  Plans  and  the  provision  of  information  for  monitoring  and 
evaluation. The amendment to this legislation was supported by a large majority of Member 
States66 and the Commission adopted it on 18 July 202467.  

For the eco-schemes, two additional variables for the area of arable land supported (for non-
productive areas and for the establishment of new landscape features) will need to be reported 
by Member States, as the current system provides only for reporting on the total area supported 
(including permanent grassland and permanent crops potentially eligible for the eco-scheme). 
The data collection is already in place, as Member States had implemented it to monitor the 
GAEC 8 first requirement. The changes are limited to ensure consistency with the basic CAP 
legislation  and  to  follow  the  implementation  of  the  simplification  measures  in  2024.   In 
addition, due to the deletion of the first requirement of GAEC 8 certain beneficiary variables 
will become redundant and, therefore, will be deleted from claim year 2025 onwards. 

In addition, the application of the temporary derogations from GAECs should be reported 
by Member States68. This is important for the Commission to be aware of the frequency or 
extent of these derogations, given their potential impact on the objectives of the CAP and to 
ensure the integrity of the policy. However, this does not entail an additional burden for farmers, 
as Member States will report the content, duration and scope of the derogations, and not which 
farmers applied the derogation and on how many hectares. 

Changes to the other GAECs do not require any further modification of the EU implementing 
legislation for data on interventions and beneficiaries69. 

Evaluation 

The evaluation of the CAP is not influenced. While the adjustments in the implementation of 
the policy will be taken into account, including derogations and exemptions to certain GAECs, 
the  overall  content  and  approach  will  not  be  affected.  The  timing  of  the  delivery  of  the 
evaluation reports, be it the interim evaluation or the ex-post evaluation70 is not concerned by 
the proposed actions. 

65 Commission Implementing Regulation (EU) 2022/1475 
66 https://ec.europa.eu/transparency/comitology-register/screen/documents/098645/1/consult?lang=en  
67 Commission Implementing Regulation (EU) 2024/1962   
68 See Explanatory Memorandum of the proposal of 15 March 2024: COM(2024) 139 final.  
69 Annex IV of Implementing Regulation (EU) 2022/1475. 
70 The SCP Regulation, Article 141. 

33 

 
 
 
7. CONCLUSIONS 

The co-legislators modernised the CAP for the 2023-2027 period, to better address societal 
concerns about sustainable farming as well as to increase the efficiency of the policy through 
a new delivery model.  

The policy’s novel approach, with performance-oriented CAP Plans and the increased level of 
ambition, demanded greater efforts and resulted in a steep learning curve for both farmers 
and national administrations. This policy shift took place in the context of the Commission’s 
ambitious Green Deal agenda and Green Deal legislative proposals, which will or may affect 
farmers both directly and through the requirements set out in the CAP Plans. Other significant 
factors  were  the  considerable  market  disturbances  due  to  the  COVID-19  pandemic,  and 
Russia’s war of aggression against Ukraine, which led to a significant increase of farmers’ costs 
and caused some farming families anxiety about their livelihoods. As the new policy was rolled 
out in 2023, these concerns found an outlet in the farmers’ wide-scale protests of early 2024, 
highlighting their concerns about EU policies. 

For this reason, the Commission decided to act immediately. In its brief consultation linked to 
this  process,  the  Commission  received  over  three  hundred  different  simplification 
suggestions from EU farming organisations, Member States and the Committee on Agriculture 
and  Rural  Development  of  the  European  Parliament.  They  cover  a  broad  range  of  policy, 
implementation,  organisation,  and  economic  issues,  and  demonstrate  the  need  to  clarify  the 
existing rules.  

The Commission carefully examined these suggestions, the provided explanations, and other 
feedback when proposing its simplification package of 22 February 2024, having weighed up 
the  advantages  and  disadvantages  of  various  options.  The  Commission  maintained  the 
overall orientation and ambition of the 2023-2027 CAP to steer the transition to sustainable and 
resilient farming, without generating unnecessary and disproportionate burdens on farmers and 
taking account  of the sector’s  recent  experience  with implementing the  CAP. This approach 
focused on solutions  that  immediately  tackle farmers’  concerns,  that better equip  national 
administrations to support and guide farmers in the necessary transition, and that help regain 
farmers’ trust.  

The resulting initiative consists of various EU legislative and non-legislative measures aiming 
to  tackle  these  complex  issues,  and  with  only  targeted  changes  to  the  policy  framework  to 
preserve its level of ambition but provide greater flexibility. The Commission also promotes 
better communication, peer exchange and guidance. 

It  is  expected  that  the  simplification  package  should  help  reduce  paperwork,  gain  time,  and 
increase flexibility in how farms are managed. This should lead to positive effects not only on 
farmers’  finances  but  also  on  their  well-being  with  fewer  stress  factors  linked  to  the 
complexity  of  the  rules,  set  against  the  day-to-day  reality  of  farming.  Better  feedback  on 
fulfilling the conditions for CAP support, and more workable monitoring and controls should 
further help in rebuilding trust and acceptance of the CAP requirements. Changes in the control 
approach alone are expected to bring at least EUR 164 million worth of savings linked to the 
reduced  time  and  effort  expended  by  farmers  and  national  administrations. These  resources 
could be dedicated, for example, to improving communication, knowledge and advice. 

These changes also reflect the fact that the cost of the transition is significant and requires 
support. The  economic  impact  of  complying  with  the  first  requirement  of  GAEC  8  alone  is 
estimated to  be  around  EUR  930 million annually. The policy mix was  thus  rebalanced and 

34 

 
 
moved  away  from  obligations  towards  incentives.  This  replacement  of  GAEC  8  first 
requirement with a voluntary eco-scheme aims to create areas for biodiversity in a way that 
takes account of farmers’ concerns and compensates them for the efforts they make, mitigating 
the  negative  impact  of  ending  the  obligation.  Providing  advice,  and  a  customised  policy 
approach, remain of utmost importance. Making requirements better adapted to specific sites 
should improve farmers’ understanding and acceptance of the environmental objectives of 
the policy and improve the environmental outcomes by avoiding counterproductive practices. 

A variety of suggestions raised in consultation submissions can already be addressed under the 
current CAP framework. Member States play a key role in reducing administrative burdens 
and  are  encouraged  to  take  advantage  of  the  increased  flexibility  they  now  have.  
The Commission will continue to assist them and help them to learn from each other to build 
confidence and avoid situations where fear of the consequences of misapplying the rules lowers 
the ambition of their CAP Plans. This should also help them to better accommodate increasingly 
unpredictable  weather  conditions  and  capitalise  on  the  benefits  of  digital  technology  for 
policy monitoring and improvement.  

In the immediate term, certain reprioritisation and/or financial adjustments of their CAP 
Plans will be necessary to back up the flexibilities in the green architecture. 

The Commission will work on completing the implementation of the simplification measures. 
Other  actions  to  reduce  the  administrative  burden  are  under  way  for  2024  and  beyond  and 
include  reducing  reporting  obligations,  while  the  outcomes  of  studies  on  the  administrative 
burden and the new delivery model will help identify further actions to simplify policies for 
farmers. The parallel workstream to improve the position of farmers in the  agri-food supply 
chain is also ongoing, to address the broader issues of farmers’ remuneration. 

Numerous other suggestions from the consultation were not taken up, so as not to change the 
fundamental elements of the 2023-2027 CAP. These ideas, as well as lessons learned from the 
implementation of the policy, will feed into the reflection on a wider policy review for the post-
2027 period, as will the outcome of the Strategic Dialogue on the Future of EU farming.  

35 

 
 
ANNEXES 

Annex 1: Actions announced by the Commission on 22 February 2024 (the simplification 
package) and their delivery. 

Action 

Delivery 

A.  Short term measures 

A.1 

Revision of GAEC 1 rules on the 
permanent grassland ratio. 

A.2 

Review of guidelines for GAEC 6. 

of 

Amendment 
the  Commission 
Delegated  Regulation  (EU)  2022/126 
adopted on 12 March 2024 (Commission 
Delegated Regulation (EU) 2024/1235) 

Obsolete  in  light  of  the  Commission 
proposal of 15 March 2024 to amend the 
CSP  and  the  Horizontal  Regulations. 
(measure B.1) 

A.3 

Revision of the EU methodology for the 
quality 
area  monitoring 
assessment. 

system 

Revised  methodology  published  on  21 
March 2024. 

A.4 

Clarify 
the  possibilities  of  using 
geotagged  photos  under  existing 
the 
legislation 
requirements  linked  to  geo-  tagged 
photos 
implementing 
the 
regulation. 

review 

and 

in 

A.5 

Explanatory note on the use of  the 
force  majeure  and  exceptional 
circumstances clause. 

of 

the 

A  clarification  note  was  discussed  with 
Member  States  on  15  May  2024. 
Presentation  and  discussion  of  the  draft 
amendment 
implementing 
regulation  in  the  Committee  on  CAP 
Strategic  Plans  on  5  June  2024.  The 
opinion of the Committee was obtained on 
11  July.  The  act  was  adopted  on  4 
September 2024 
(Commission Implementing Regulation 
(EU), C(2024)6069 final)  
Communication of 30 May 2024 from the 
Commission  to  the  Council  on  force 
majeure  and  exceptional  circumstances 
(COM(2024)225 final) 

A.6 

Rationalising  controls,  including  the 
right of  error. 

Discussed  with  Member  States  in  the 
expert group meeting on 26 April 2024. 

A.7 

Organise 
the  exchange  of  best 
to 
practices  with  Member  States 
simplify  interventions  and  minimise 
the 
of 
conditionality, eco-schemes and rural 
development interventions. 

administrative 

burden 

the 
Exchange  of  best  practices 
Thematic  Group  on  Green  Strategies 
organised  by  the  CAP  Network  on  11 
April and 4 June 2024. 

in 

36 

 
 
Action 

Delivery 

A.8 

Encourage Member States to reinforce 
the role of, and budgetary support for, 
advisory  services  to  assist  farmers  in 
complying  with  obligations  and 
accessing CAP support. 

Note  sent  to  Member  States  on  12  April 
2024. 

A.9 

Improve  CAP  Plans  amendment 
procedure. 

Note to Member State experts presented in 
the  Expert  Group  on  the  CAP  Strategic 
Plans on 9 April 2024. 

A.10 

Encourage  stakeholders 
to  submit 
views on the administrative burden of 
the Nitrates Directive, in consultation, 
for the purposes of  the evaluation of 
the directive. 

B. Mid-term/long term measures 

B.1 

Review  of  GAEC  8  and  possible 
extension  of  the  review  to  other 
GAECs,  notably  GAEC  6  and  7,  for 
2025-2027. 

Public  consultation  closed  on  8  March 
202471. 

Addressed via the  Commission  proposal 
of 15 March 2024 to amend the CSP and 
the  Horizontal  Regulations. Adopted  by 
the  co-legislators  and  published  on  24 
May 2024. It entered into force on 25 May 
2024  (Regulation  (EU)  2024/1468,  the 
Simplification Regulation). 

B.2 

Exemption  of  small  farms  (under  10 
ha) from conditionality controls. 

As above. 

B.3 

Exemption  for  organic  farmers  from 
GAEC 7 and GAEC 8 requirements. 

to 
Exemption  of  farmers  subject 
conditionality  from  cross-compliance 
controls. 

Obsolete  with  the  deletion  of  the  first 
requirement  of  GAEC  8  (measure  B1). 
Organic farmers are already deemed to be 
compliant with GAEC 7. 

Addressed  via  the  Commission  proposal 
of 15 March 2024 to amend the CSP and 
the  Horizontal  Regulations.  Adopted  by 
the  co-legislators  and  published  on  24 
May 2024. It entered into force on 25 May 
2024  (Regulation  (EU)  2024/1468,  the 
Simplification Regulation). 

Review 
amendments of the CAP Plans. 

the  number  of  possible 

As above. 

Exchange  of  best  practice  to  better 
coordinate  the  control  systems  of 
climate,  environmental  and  animal 
legislation  with  CAP 
welfare 

A  first  discussion  with  Member  States 
took place in the expert group meeting on 
26 April 2024. 

B.4 

B.5 

B.6 

71 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14051/public-consultation_en  

37 

 
 
 
Action 

Delivery 

conditionality 
through meetings of expert groups. 

controls, 

including 

B.7 

B.8 

B.9 

remote  sensing  services  as 
Use 
provided  for  in  the  proposed  Soil 
Monitoring Law and proposed Forest 
Monitoring  Law  for  assessing  soil 
health and for forest monitoring. 

Exempt  plant  protection  products 
containing  only  biological  active 
record  keeping 
substances 
obligations. 

from 

requirement 
submit 

that 
Eliminate 
the 
individual 
farmers  must 
applications  for  aerial  spraying  of 
plant 
once 
protection 
relevant conditions are met. 

products 

B.10 

Eliminate the requirement for farmers 
to  keep  records  of 
treatment  of 
animals  with  medicinal  products 
under Directive 98/58/EC. 

C.  Evidence gathering 

C.1 

Study on simplification and the 
administrative burden on farmers 
under the CAP. 

After adoption of the legal texts. 

Consideration  of  a  proposal  to  amend 
Article  67(1)  of  Regulation  (EC)  No 
1107/2009. 

Consideration  of  a  proposal  to  amend 
Article 9(4) of Directive 2009/128/EC. 

Consideration  of  a  proposal  to  amend 
Directive 98/58/EC. 

Survey addressed to farmers launched on 
7 March and closed on 8 April 2024. 

First  results  published  on  Europa  on  12 
April  2024  (with  update  of  7  October 
2024). 

In-depth 
selected respondents in spring 2024. 

follow-up 

interviews  with 

C.2 

Study on the administrative burden and 
the new delivery model of the CAP. 

Study launched and to be concluded in Q4 
2025. 

Study to be completed by beginning 2025. 

38 

 
 
 
 
Annex 2. Overview of the simplification suggestions received  

This  is not a legally binding  document.  It was prepared by  the departments  of the  Commission and does not  commit the European Commission.  The 
explanations, which are part of the assessments of the simplification suggestions submitted by Member States and stakeholders in respect of certain EU 
legal acts are provided for information purposes only. In the event of a dispute involving EU law, under the Treaty on the Functioning of the European 
Union, it is ultimately for the Court of Justice of the European Union to provide a definitive interpretation of the applicable EU law. 

I. CAP STRATEGIC PLANS – MINIMUM REQUIREMENTS, FINANCING, MANAGEMENT, PERFORMANCE 

Suggestions 

Proponents 

Assessment 

Definitions and minimum requirements 

Permanent grassland: greater flexibility for Member States to 
define  the  onset  of  permanent  grassland/pasture  including 
reference dates. No mapping of ineligible features on grasslands 
(e.g. bushes). All species typically found on grasslands belong 
to permanent grassland. 

DE 

Permanent grassland: call to introduce a buffer tolerance for 
small patches of permanent grassland that lie within arable land. 
They should be classified with the same crop as the surrounding 
arable land. 

DK, FI 

1 

2 

The  definition  of  permanent  grasslands,  including  reference  dates,  is 
already  very  flexible  as  Member  States  set  the  definition  of  permanent 
grasslands in their CAP Plans within a framework definition laid down in 
the CSP Regulation. It is for Member States to define the plant species to 
better  reflect  local  specificities,  including  bushes  when  they  are  not 
predominant  and  do  not  significantly  hamper  the  performance  of  the 
agricultural  activity  (in  accordance  with  Article  4(4)(b)  of  the  CSP 
Regulation). The mapping is necessary to ensure that ineligible features 
are not predominant. 

It  is  already  possible  to  address  this  issue  within  the  current  EU  CAP 
framework.  Small  areas  inside  arable  land  may  be  classified  as  ‘other 
landscape  feature’  in  accordance  with  Article  4(4)(b)  of  the  CSP 
Regulation. 

39 

 
 
 
Suggestions 

Proponents 

Assessment 

3 

4 

5 

6 

Eligible hectare: call to reduce the complexity of the eligible 
hectare definition for areas covered by non-productive areas and 
landscape features by allowing them to predominate in the area 
for biodiversity purposes. Article 4(4)(b) of the CSP Regulation. 

DK 

For permanent grassland, the CSP Regulation makes it possible to apply 
fixed  reduction  coefficients  to  determine  the  area  considered  eligible, 
even if the ineligible features are predominant. Lessons learned from the 
current period will feed into the reflection on the post-2027 CAP. 

Livestock  farming:  particular  attention  must  be  given  to 
pastoral  livestock  farming,  which  must  benefit  from  more 
flexibility  on  the  eligibility  of  pastoral  areas,  in  particular 
authorising those with woody resources. 

ECVC 

Member  States  have  substantially  more  flexibility  in  determining 
eligibility  rules  for  direct  payments,  including  for  woody  pastures, 
compared to rules before the 2021 CAP reform. Lessons learnt from the 
current period will feed into the reflection on the post-2027 CAP. 

Active farmer: remove active farmer criteria and replace them 
with criteria for minimum area/number of animals. Article 4(5) 
of the CSP Regulation. 

DK 

Non-productive areas: allow the presence of sheep and goats 
(and  grazing  by  them)  on  non-productive  areas  required  / 
financed under the CAP (conditionality, eco-schemes, AECC). 

DE 

This issue can be addressed within the current EU CAP framework. The 
active farmer definition is one of the tools for targeting CAP support. The 
current framework definition of ‘active farmer’ laid down in Article 4(5) 
of the CSP Regulation is already flexible enough to accommodate diverse 
national implementation needs.  

This suggestion seems partly linked to the ‘non-productive areas’ under 
the  first  requirement  of  GAEC  8,  which  has  been  deleted  by  the 
Simplification  Regulation.  As  regards  interventions,  Member  States 
define  the  eligibility  conditions  and  commitments,  including  elements 
related  to  maintenance  of  areas.  With  regard  to  the  concept  of  ‘non-
productive areas’ under GAEC 8, first requirement, the Commission has 
already clarified that, if compatible with the main objective of that GAEC, 
certain  non-productive  grazing  practices  (e.g.  taking  place  outside  the 
flowering season) could take place on such areas. 

40 

 
 
Suggestions 

Proponents 

Assessment 

The  Simplification  Regulation  deleted  from  GAEC  standard  8  the 
requirement to maintain non-productive areas and features on arable land. 
In addition, under Article 13(2a) of the amended CSP Regulation Member 
States may also grant new temporary derogations from GAEC standards. 
Blanket exemptions for non-productive areas under eco-schemes and agri-
environment-climate commitments would hamper the achievement of the 
specific objectives of the CAP. 

The current EU CAP framework is flexible and can accommodate diverse 
national needs. It is up to the Member States to determine ‘the appropriate 
training or skills’ that are required.  

DE 

LT 

ECVC 

The  requested  simplification  and  other  actions  largely  fall  within  the 
scope of Member States’ responsibilities and thus beyond the remit of the 
Commission’s role in the shared management of the CAP.  

7 

8 

9 

Non-productive  areas:  possibility  to  use  non-productive 
parcels no matter whether under GAEC 8 standard, eco-schemes 
or  agri-environmental  measures  in  extraordinarily  dry  or 
extraordinarily  wet  (with  flooded  areas)  years  for  grazing  or 
feed use. 

Young  farmers:  exclude  the  ‘appropriate  training  or  skills’ 
requirement under the qualification as a 'young farmer’. Article 
4(6)(c) of the CSP Regulation. 

Changes in and by national administrations:  

-  Ensure effective transfer of information within the national 
administration and/or control bodies. A document given to 
one administrative service by the farmer should no longer 
have to be given to another service; 

-  Improve  the  accessibility  of  letters  sent  to  farmers.  Their 
opaque nature generates questions and stress on the ground; 
-  Allow  farmers to  operate  directly  on  their  farm  file  in  all 
European countries without the need for intermediaries; 
-  Process  appeals  within  a  reasonable  time  frame.  Set  a 

maximum deadline for administrations; 

-  Do  not  rely  on  the  hyper  technologisation  of  processing 
everything administrative. In addition, the use of data, if it 
is not truly protected, is a threat; 

-  Ensure  the  presence  of  real  people,  informed  public 

administration personnel, to help with procedures; 

-  Limit the number of inspections on farms and their duration; 

41 

 
 
Suggestions 

Proponents 

Assessment 

-  Review the checklist of controls as it is too broad - in certain 

cases; 

-  Guarantee real simplification of permit applications (rapid 

processing without administrative complexity). 

CAP Strategic Plan (CSP) management 

10 

Level of detail: less detailed  CAP Plan with a more strategic 
approach. Detailed descriptions of requirements should be left 
to  national  authorities.  Simplify  obligations  in  terms  of 
monitoring, reporting and other tasks. 

11 

Amendments:  simplify  the  CAP  Plan  amendment  procedure. 
Speed  up  the  negotiation  of  the  CAP  Plan  amendments  and 
amendment procedures.  

The design of CAP Plans, including choices that affect their complexity, 
as  well  as  implementation  are  the  responsibility  of  Member  States. 
Member  States  are  encouraged  to  simplify  the  description  of  the 
interventions  in  their  future  amendments  of  the  CAP  Plans.  The 
Commission services are committed to continue implementing a ‘need to 
know’  approach,  by  targeting  their  request  on  issues  relevant  for  the 
assessment  and  approval  of  the  amendments,  working  with  Member 
States and substantially reducing the level of detail demanded in the CAP 
Plan  approval  process,  while  ensuring  a  level  playing  field  between 
Member States and a continued focus on the CAP Plans’ objectives and 
on performance. An open, constructive, and transparent dialogue between 
the Commission services and national authorities, based on advanced and 
complete proposals, helps speed up the approval process. Lessons learned 
from the current period will feed into the reflection on the post-2027 CAP.  

This suggestion is covered by the Simplification Package. A review of the 
CAP  Plan  approval  process  is  ongoing  in  the  remit  of  the  discussion 
between the Member States and the Commission in the relevant expert 
groups.  

CZ, EE, EL, 
HU, LV, MT, 
SE, SI, DK, 
CY 

ECVC, CEJA 

All Member 
States (except 

DE and ES) 

COPA-
COGECA,  

CEJA,  

COM AGRI 

42 

 
 
 
Suggestions 

Proponents 

Assessment 

12 

Amendments:  CAP  Plan  amendment  frequency  should  be 
increased. 

EL, LT, LV, 

PL, RO 

The suggestion is covered by the simplification package. The Commission 
proposed to increase the maximum number of requests for amendment of 
CAP  Plans  which  a  Member  State  may  submit  per  calendar  year. 
Following the amendment of Article 119(7) of the CSP Regulation by the 
Simplification Regulation, Member States are now allowed to send two 
requests per calendar year.  

Amendments:  apply  the  notification  procedure  in  Article 
119(9)  of  the  CSP  Regulation  for  modifications  of  CAP  Plan 
interventions  financed  by  the  European  Agricultural  Fund  for 
Rural  Development  (EAFRD)  also  to  those  financed  by  the 
European Agricultural Guarantee Fund (EAGF). Harmonise the 
provisions  regarding  the  entry  into  force  of  the  amendment 
proposals  for  Pillar  I  interventions  (EAGF)  with  the  current 
provisions for Pillar II (EAFRD). 

BG, CZ, EE, 
EL, FR, HR, 
PL, SI, SK, 

IE, BE 

Lessons learned from the current period will feed into the reflection on 
the  post-2027  CAP,  taking  into  consideration  the  annual  nature  of  the 
EAGF and the difficulties farmers may face in adapting to changes that 
would take effect during the claim year. 

13 

14 

Amendments: allow retroactive application of amendments or 
the ability to apply modifications retroactively in certain cases 
without,  however,  going  back  before January  1  of the  year in 
which the modification is introduced (to avoid generating legal 
uncertainty and regulatory instability).  

BG, EL, HR, 
HU, MT, FR 

15 

Amendments:  validity  of  CSP  amendments  as  of  the  date  of 
submission.  Harmonisation  of  provisions  regarding  the  entry 
into force of the amendment proposals for EAGF interventions 

EL 

43 

The suggestion was not taken up because it does not take into account the 
differences between the EAGF,  which  covers annual interventions, and 
the EAFRD, which is mainly multiannual. The annual nature of the EAGF 
cannot be reconciled with retroactive changes for previous financial years. 
Besides,  any  retroactive  changes  to  requirements  which  would  be 
mandatory  for  farmers  risk  affecting  legal  certainty  and  the  legitimate 
expectations of farmers, and may also entail a risk of discrimination. EU 
legislation, as well as its implementation, needs to respect these general 
principles of EU law, as laid down in Article 9 of the CSP Regulation, and 
also reflected in Article 119(8), third subparagraph, of that Regulation, 
for EAGF-related amendments of CAP Plans.   

The  suggestion  was  not  taken  up  considering  that  this  would  require  a 
review of the approval process of the CAP Plans, contradicts the strategic 
approach of the CAP Plans, and could not be reconciled with the annual 

 
 
Suggestions 

Proponents 

Assessment 

with  the  current  provisions  for  EAFRD  interventions.  The 
validity  of  the  amendments  from  the  date  of  their  official 
submission to the EU services to be applied for Pillar I as well, 
especially for the sectoral interventions. 

16 

Approval: flexibility in the approval of the CAP  Plans in cases 
where  similar  solutions  have  already  been  accepted  by  the 
Commission. 

PL 

nature of the EAGF. This proposal also entails risks from the perspective 
of legal certainty and legitimate expectations of the farmers that would be 
affected  by  such  changes,  in  particular  as  regards  the  mandatory 
requirements that they need to meet.    

When assessing the proposed CAP Plans as well as their amendments, the 
Commission  considers  the  entire  intervention  strategy  to  address  the 
specific needs defined by the Member State under each specific objective, 
as well as, among other things, complementarity and consistency of the 
various  elements  in  the  CAP  Plan  (see  Article  118(2)  of  the  CSP 
Regulation).  It  would  therefore  not  be  possible  for  the  Commission  to 
approve an amendment to a CAP Plan merely on the grounds that another 
Member State has already introduced a similar amendment.    

Article  119(8),  third  subparagraph  of  the  CSP  Regulation  already 
provides safeguards as regards entry in effect of CAP Plan amendments, 
as it requires Member States proposing a date of effect for EAGF-related 
amendments  (including  for  conditionality)  to  consider  the  need  for 
farmers to have sufficient time to take the amendment into account. It is 
for Member States to decide when to submit a request for amendment of 
the CAP Plan. Such requests for amendment should therefore be timed in 
a  way  that  allows  farmers  to  be  informed  well  in  advance  and  to  have 
sufficient time to take the amendment into account.  

Timing  of 
implementation:  new  standards  should  be 
communicated  at  least  one  year  before  their  implementation 
(transition period) and under no circumstances should they be 
voted on and communicated urgently.  

ECVC, CEJA 

17 

18 

Involvement  of  national  agencies  in  the  policy  evaluation: 
paying  agencies  and  other  authorities  implementing  the  CAP 
should be systematically involved in the evaluation of the policy 
and the preparation of new reforms, particularly when it comes 
to the new governance logic. When reflecting on the CAP post 
2027,  it  is  crucial  to  objectively  assess  how  national strategic 

CEJA  

The Commission is regularly in contact with paying agencies and national 
authorities. Governance and implementation are important aspects of the 
Commission’s evaluations and impact assessments before adopting policy 
proposals. Member State authorities have an important responsibility to 
ensure policies are implemented in simple and efficient ways. 

44 

 
 
Suggestions 

Proponents 

Assessment 

plans  have  weighed  on  those  agencies  and  whether  their 
capacity could be improved in the future. 

Establish  better  priorities  and  communication  around 
agricultural policies: when formulating priorities and policies, 
it  is  essential  to  highlight  that  farmers,  in  their  business 
decisions, will need to make choices, implementing progressive 
change  rather  than  a  radical  one.  Changing  narratives  around 
agricultural policies will be a key success factor, not only for the 
CAP but also for every farm around the EU. 

19 

CEJA 

The Commission aims to communicate clearly about the CAP as well as 
other  EU  policies  affecting  farmers.  Moreover,  the  EU  co-finances 
projects to inform the public about the CAP. 

20  Unit amount: unit amount for projects and flat rate/area-based 

interventions considered burdensome. 

21  Unit amount: request to abolish the unit amount approach (and 

focus instead on outcome and result indicators). 

CZ 

LV 

These suggestions were not taken up. Unit amounts are an element in the 
management  and  monitoring  of  CAP  implementation  under  the  CSP 
Regulation. Feasibility and impact of changes pertinent to this approach 
are under consideration (see also suggestion 120). Lessons learned from 
the first year(s) of implementation will be considered. 

Unit amounts 

22  Unit  amount:  enable  amendment  of  unit  amounts  for  direct 

payments during the year. 

BG, CZ, EE 

The  suggestion  was  not  taken  up,  as  it  would  create  uncertainty  for 
farmers  and  impact  their  legitimate  expectations.  Some  degree  of 
flexibility is available within the current EU legal framework, e.g. as laid 
down in Article 102 of the CSP Regulation. Lessons learned from the first 
year(s) of implementation will be considered.  

23 

Advance  payments:  increase  the  level  of  advances  and/or 
technical changes in relation to advances, such as introducing 
advances without a bank guarantee. 

CZ, FR, FI, 
HR 

These suggestions were not taken up. With the adoption of the CSP and 
the  Horizontal  Regulations,  possibilities  for  advances  were  already 
expanded. In addition, bank guarantees secure the EU’s financial interests. 

Budget and financial management 

45 

 
 
24 

25 

26 

27 

28 

29 

30 

31 

Suggestions 

Proponents 

Assessment 

Advance  payments:  simplification  of  advance  payments  to 
help farmers with liquidity problems. Member States should be 
given more room for manoeuvre to pay advances, with possible 
overpayments taken care of by means of a recovery process. 

FI 

COPA-
COGECA 

Member States are allowed to pay advances before checks are finalised, 
subject  to  the  rules  laid  down  in  the  Horizontal  Regulation,  but  they 
should have a functioning mechanism to recover undue payments. 

EAGF:  simplify  financial  management  of  direct  payment 
intervention 

CZ 

Lessons learned with regard to financial management will feed  into the 
reflection on the post-2027 CAP. 

EAGF: reduce the obligation of annual financial planning, or 
switch to multiannual financial management for the EAGF. 

CZ, NL, LU 

Lessons learned with regard to financial management will feed  into the 
reflection on the post-2027 CAP. 

Transfers: more flexibility for transfers between pillars (Article 
103(5) of the CSP Regulation). 

PT, RO, BE 

The suggestion was not taken up. To ensure the stability of programming, 
the  co-legislators decided  to  limit the possibility  to modify  transfers  of 
allocations between funds to once during the five-year period of the CAP 
Plans. 

Transfers:  flexibility  for  transfers  between  direct  payment 
allocations  and  EAFRD  allocations  –  allow  review  of  CAP 
Plans already in 2024 (instead of 2025)  (Article 103(5) of the 
CSP Regulation). 

Transfers:  flexibility  in  reallocation  of  unused  funds/direct 
payments  e.g.,  between  interventions  and/or  making  them 
multiannual. 

Transfers:  flexibility  in  reallocation  of  unused  funds  under 
2014-2022  Rural  Development  Programme  beyond  2025  (to 
CAP Plans or a national fund). 

Undue/excessive  payments:  reintroduction  of  provisions  on 
unduly or excessively granted payments - up to EUR 100. 

PL 

The suggestion was not taken up, as enabling review of the transfers in 
2024  would  result  in  uncertainty  for  beneficiaries,  considering  that 
implementation of CAP Plans for 2024 is ongoing.    

The  suggestion  was  not  taken  up.  The  limitations  on  reallocation  are 
linked to the annual budgetary nature of EAGF appropriations, and this 
cannot be changed under this MFF. 

The  suggestion  was  not  taken  up.  Member  States  are  encouraged  to 
implement and complete their 2014-2022 rural development programmes. 
Reallocation  of  unused  funds  beyond  2025  is  not  possible  from  a 
budgetary perspective. 

This suggestion was not taken up. This reflection can take place in the 
post-2027 CAP discussion. 

EL, SK, BE 

DK 

PL 

46 

 
 
Suggestions 

Proponents 

Assessment 

32 

33 

34 

35 

EAFRD:  abolish the requirement to set annual funding for each 
rural  development  intervention.  Delete  the  detailed  financial 
tables in descriptions of interventions. 

LV 

Lessons learned with regard to financial management will feed  into the 
reflection on the post-2027 CAP. 

EAFRD: change of the automatic decommitment rule from N+2 
to N+3 with regard to EAFRD as applicable to other investment 
the  Horizontal 
and  structural  funds  (Article  34(1)  of 
Regulation). 

EAGF/EAFRD: request to place EAFRD and EAGF under the 
Common Provision Regulation (Regulation (EU) 2021/1060) to 
make it easier for Member States to adopt similar systems across 
different shared management funds at national level. 

Simplified Cost Options (SCO): introduction of a system that 
enables a Member State to ask for ex ante legal assurance on the 
different forms of financing applied e.g. simplified cost options. 

MT 

MT 

The N+2 decommitment rule for the new CAP was decided in the context 
of the political agreement for the current MFF in 2020, and it was later 
enshrined in the CAP Horizontal Regulation by the co-legislators in 2021.  
The rule ensures a timely implementation of the CAP Plans, to the benefit 
of the CAP beneficiaries. It also facilitates a steady delivery on the targets 
and objectives of the Plans. Any delay should be avoided as it puts at risk 
the performance of the CAP Plans. 

The  suggestion  was  not  taken  up.  With  the  adoption  of  the  CSP 
Regulation,  the  co-legislators  decided  to  take  the  EAFRD  out  of  the 
Common Provision Regulation to improve synergies between the EAGF 
and the EAFRD. 

The  suggestion  was  not  taken  up.  The  legal  assurance  comes  from  the 
choice of SCO and is not approved ex ante by the Commission. 

IACS - Integrated administration and control system 

36 

IACS should be optional. Control should only be within 
national competence. 

37 

IACS should be simplified.  

The  suggestion  was  not  taken  up.  Despite  all  the  flexibility  granted  to 
Member States under the new delivery model of the CAP, there remains 
a need for assurance and protection of the EU’s financial interests. Also, 
this would distort the level playing field between Member States under 
the EU CAP framework. 
Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

NL 

SE 

47 

 
 
 
Suggestions 

Proponents 

Assessment 

IACS – identification of beneficiaries 

Information on beneficiaries: allow Member States to decide 
whether to request information from farmers or obtain this from 
(Article  44  of  Commission 
another  authentic 
Implementing Regulation (EU) 128/2022). 

source 

BE 

Addressing  this  issue  is  already  possible  within  the  current  CAP 
framework. 

IACS – identification of parcels (LPIS) 

Land  parcel  identification  system  (LPIS)  update:  in  the 
northern  conditions  (late  spring,  snow  cover),  the  digitised 
information from the update of the LPIS should be used in the 
aid  applications  only  for  the  following  year  (Article  2(5)  of 
Commission Delegated Regulation (EU) 2022/1172).  

FI 

The suggestion was not taken up. The LPIS should be updated within 3 
years. Any known need for update triggered by the AMS, geo-spatial aid 
application or other reliable information should be taken into account to 
give the correct and latest information to the farmers for their declarations. 

Aid applications – submission and withdrawal 

Automatic  enrolment:  a  possibility  to  provide  for  automatic 
enrolment  in  schemes  (e.g.  ANC)  unless  farmers  choose  to 
withdraw and notify their withdrawal.   

IE 

This is already possible under the current EU CAP framework. It is for 
Member States to design and implement the application system for CAP 
aid, including these elements.  

Single aid application: establish a single aid application period 
for all interventions. 

COPA-
COGECA 

The  obligatory  single  application  was  abolished  by  the  co-legislators. 
However, Member States may choose to apply a single application if they 
wish  and  decide  the  application  period  in  line  with  the  Horizontal 
Regulation and Commission Implementing Regulation (EU) 2022/1173. 

Modification:  farmers  should  be  allowed  more  flexibility  to 
modify their payment applications after the deadline so that they 
can better respond to the changing situation in agriculture. 

PL 

This is already catered for, as Member States have flexibility in designing 
their  control  and  penalty  system.  This  is  one  of  the  key  advantages  in 
applying the AMS. However, a deadline for aid application amendments 

38 

39 

40 

41 

42 

48 

 
 
Suggestions 

Proponents 

Assessment 

Modification/withdrawal:  allow 
to  change  or 
withdraw  their  aid  application  after  detection  of  any errors to 
avoid  sanctions  and/or  when  detection of  non-compliance  has 
happened,  also  by  means  other  than  the  AMS  (Article  7  of 
Commission Implementing Regulation (EU) 2022/1173). 

farmers 

BG, HU, 

RO, SK 

Payments: allow payments to be made to farmers selected for 
inspections  (with  a  fixed  amount  withheld  for  possible 
penalties). 

Payments: the Commission to issue a guidance note regarding 
farmers selected for inspection.  This is to clarify that Member 
States are allowed to pay farmers the majority of their payment 
while holding back a fixed amount to cover possible penalties. 

IE 

IE 

is necessary to ensure a proper administration of interventions, and it was 
set as late as possible, just 15 days before the first payment. 

The suggestion was not taken up. The right to amend the application is 
linked to the use of the AMS as only the monitoring approach allows for 
such a preventive approach. This is to ensure the legality and regularity of 
payments. When all beneficiaries for a given intervention are not covered 
by  administrative  checks  and/or  by  the  use  of  the  AMS,  the  deterrent 
effect of sanctions is still necessary. 

Designing  the  control  and  penalty  system  is  up  to  Member  States, 
however, the penalty should be independent from how a Member State 
decides to control an eligibility condition. 

The  EU  CAP  framework  allows  Member  States  to  introduce  this 
possibility  as  they  have  flexibility  in  designing  the  control  and  penalty 
system. 

The  Horizontal  Regulation  does  not  empower  the  Commission  to  issue 
such  guidance.  It  is  for  Member  States  to  design  and  implement  these 
elements. 

IACS – Area Monitoring System (AMS) 

AMS flexibility: simplify, clarify, and make more flexible the 
implementation  of  the  AMS  and/or  leave  the  extent  of  its 
application to Member States’ discretion. 

EE, MT, PL, 
BE, CZ 

the 
Exploit  agri-dataspaces:  when  designing  measures, 
possibilities  of  future  agri-dataspaces  should  be  explored  and 
(reduced 
exploited 

the  management  of  measures 

in 

BE 

49 

The current EU CAP framework already provides flexibility for Member 
States  to  choose  their  own  solutions.  In  addition,  in  the  simplification 
package the Commission proposed to make the use of geotagged photos 
under the AMS voluntary. 

The Commission is closely following the development of the Common 
European agricultural data space (CEADS) as well as related initiatives 
that promote a more efficient re-use of data. CEADS should consider the 

43 

44 

45 

46 

47 

 
 
Suggestions 

Proponents 

Assessment 

49 

50 

51 

administrative burden for farmers and less calendar farming). It 
should be possible to align the grant conditions with an AMS-
based approach (more generic conditions).  

48 

Control burden under the AMS, quality assessment should be 
reduced. 

CY, LU 

Flexibility  in  controls:  Member  States  should  have  greater 
leeway in choosing control methods 

BE, FI, SE 

needs of both farmers and public administrations. In this set-up period of 
the CEADS, support from Member States to ensure delivery of data for 
public use would be greatly appreciated.  

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP and on the potential role of data from the CEADS to 
improve the design of measures while reducing reporting needs. 

Within the simplification package the Commission revised the EU-level 
methodology for IACS quality assessment.  This included changes to the 
AMS quality assessment sampling approach, allowing the reduction of the 
control burden under the AMS quality assessment.  

It  is  already  possible  to  address  this  issue  within  the  current  EU  CAP 
framework.  Member  States  fix  their  own  control  systems,  except  for 
controls related to conditionality.  

Timing of AMS: postpone introduction of full AMS from 2024 
to 1 January 2025 (Article 70(1) of the Horizontal Regulation). 

RO, HU, BG, 
SK, HR, BE 

The  suggestion  was  not  taken  up.  The  AMS  should  have  been  fully 
operational by 1 January 2024. 

Satellite imagery: request to the Commission to provide high 
resolution 
effective 
monitoring/implementation,  to  avoid  the  need  for  on-the-spot 
checks 

satellite 

images 

for 

HU, EL, FR, 
MT, BE 

The  Commission  provides  Member  States  with  very  high  resolution 
(VHR) imagery for the IACS quality assessments, and it is for the Member 
States to decide how to use them in an efficient way, including for their 
control system, to reduce the number of on-the-spot-checks. 

The Commission has no budget to buy VHR imagery for ordinary control 
purposes. It is for Member  States to design interventions which can be 
easily and cost-efficiently controlled. 

50 

 
 
Suggestions 

Proponents 

Assessment 

52 

Scope of the AMS: leave it to Member States’ discretion which 
interventions and/or eligibility requirements fall under the AMS 
(monitoring, quality assessment and reporting). (Article  10 of 
Commission Implementing Regulation (EU) 2022/1173) 

DE, PL 

This is already the case as Member States categorise eligibility conditions 
as  monitorable  and  non-monitorable  and  also  design  the  interventions. 
Within the simplification package, the Commission proposed to make the 
use of geotagged photos under the AMS voluntary. 

53 

Risk sample. request to exclude the risk sample from the AMS 
system (Article 60 of the Horizontal Regulation). 

CZ 

Scope of the AMS: delete the obligation that at least 70% of 
interventions with eligibility criteria that can be monitored only 
with  geotagged  photos  will  be  subject  to  the  area  monitoring 
system  before  1  January  2027.  Geotagged  photos  should  be 
optional.  AMS  verification  should  only  cover  satellite 
verification  and  related  requests  to  farmers  for  additional 
information 
(4)  of  Commission 
(Article  10 
Implementing Regulation (EU) 2022/1173) 

(3)  and 

Geotagging: longer phasing in of the compulsory use of geo- 
tagged  photos  (such  as  from  2026  in  place  of  2025)  (Article 
10(3)  of  Commission 
(EU) 
2022/1173). 

Implementing  Regulation 

Geotagging:  eligibility  conditions  that  can  be  controlled  by 
geotagged  photos  should  not  be  considered  as  monitorable 
conditions.  These  conditions  should  be  subject  to  a  control 
sample. 

54 

55 

56 

The EU CAP framework leaves it to Member States to design their control 
system. The risk-based sample applies only to the classic control systems 
under  Article  72  of  the  Horizontal  Regulation.  There  is  no  risk-based 
sample under the AMS provisions.  

The suggestion was addressed by the simplification package by making 
use  of  geotagged  photos  under  the  AMS  voluntary  (Commission 
Implementing  Regulation  (EU),  C(2024)  6069  final).  Moreover,  the 
Commission has engaged to alleviate the administrative burden linked to 
geotagging while maintaining the benefits of this technology to reduce on-
the-spot checks and ensure controllability of CAP spending.  Geotagged 
pictures are also a means to detect possible issues at an early stage, giving 
the applicant the possibility to rectify them to avoiding penalties.  

AT, BE, DE, 
ES, FI 

BG, HR, 

HU, SE 

The suggestion was not taken up. Within the simplification package, the 
Commission decided to make the use of geotagged photos under the AMS 
voluntary (see above). Therefore, there is no need for a longer phasing in. 

Within the simplification package, the Commission decided to make the 
use of geotagged photos under the AMS voluntary (see above). As such, 
in the scope of the AMS it is for Member States to decide if eligibility 
conditions monitorable by geotagged photos are classified as monitorable 
or not. However, considering an eligibility condition as monitorable is to 

DK 

51 

 
 
Suggestions 

Proponents 

Assessment 

Use of geotagged images for controls: the burden of proof lies 
on the applicant. Member States should have more flexibility to 
select an appropriate control method in cases where the AMS 
cannot  be  used.  The  use  of  geo-referenced  images  should  be 
introduced only in cases where they bring clear benefits to the 
applicant.   

COPA-
COGECA 

the advantage of the farmer due to its preventive approach, in contrast to 
the classic ex post (sample based) control approach. 

The  Commission  has  engaged  to  alleviate  the  administrative  burden 
linked  to  geotagged  photos,  while  maintaining  the  benefits  of  this 
technology to reduce the burden of on-the-spot controls on farmers and 
ensure controllability of the CAP spending. 

Member States may choose to combine data from satellite images and data 
from  geotagged  photos.  Member  States  can  also  choose  to  perform  a 
cascaded analysis of satellite images and geotagged photos to reduce the 
number of non-conclusive monitored cases. It is up to Member States to 
decide if an eligibility condition is monitorable only via geotagged photos. 

Quality assessment of IACS components 

Abandon the quality assessment (as an alternative to changing 
it) (Articles 68, 69 and 70 of the Horizontal Regulation, Articles 
3,  4  and  5  of  Commission  Delegated  Regulation  (EU) 
2022/1172). 

DE, BE 

Scope:  modify  the  IACS  quality  assessment  rules  to  remove 
obligatory inclusion of all GSA parcels (Articles 3, 4 and 5 of 
Commission Implementing Regulation (EU) 2022/1172). 

60 

Scope: IACS quality assessment – samples only at intervention 
level. 

The suggestion was not taken up. Quality assessment ensures information 
about the reliance of the system and the correctness of the data provided 
for  indicators  linked  to  area-based  interventions.  It  also  aims  to  be  an 
incentive  to  improve  Member  States’  IACS  systems  and  continue 
digitalisation. 

The suggestion was not taken up. Fair treatment of farmers, impartiality 
and reliability of the quality assessment requires the sampling of the whole 
population. 

The suggestion was not taken up. Fair treatment of farmers, impartiality 
and reliability of the quality assessment requires the sampling at level of 
Unit  Amounts  or  Group  of  Unit  Amounts  with  similar  eligibility 
conditions  to  the  whole  population.  IACS  quality  assessments  ensure 
information  about  the  correctness  of  the  data  provided  for  indicators, 

57 

58 

59 

BG 

DE 

52 

 
 
Suggestions 

Proponents 

Assessment 

61 

62 

63 

Scope:  IACS  quality  assessment  should  be  limited  to  the 
effectiveness  of  this  system  –  exclude  information  related  to 
indicators (Article 5(1), (2) and (5) of Commission Delegated 
Regulation (EU) 2022/1172). 

Scope:  geospatial  application  quality  assessment  -  area 
measurement should only be done on parcels covered by VHR 
imagery provided by the EU/Commission. 

Scope:  call  to  limit  the  AMS  quality  assessment  only  to 
monitorable requirements. Non-monitorable and administrative 
checks  should  be  left  outside  the  scope  of  AMS  quality 
assessment(Article  5(5)  of  Commission  Delegated  Regulation 
(EU)2022/1772). 

64 

Scope: the AMS quality assessment should be implemented in 
such a way that it only assesses the system and its functionality 
and does not function as a parallel control system, as is currently 
the case.  

which are reported at the level of Unit Amount, and not at the intervention 
level. 

The suggestion was not taken up. Within the simplification package, the 
Commission  revised  the  EU-level  methodology,  in  which  the  AMS 
methodology  was  included,  allowing  reduction  of  the  control  burden 
under the AMS quality assessment.  

The quality assessment methodology already considers the location of the 
satellite  imagery  and  focuses  on  these  parcels.  It  is  noted  that  not  all 
Member States request VHR imagery. 

The suggestion was not taken up. The sample should be drawn from the 
whole population. Such a change would heavily impact the reliability of 
the quality assessment and would also limit to farmers the profits of the 
preventive approach embedded in the AMS. The latest revision of the EU-
level  methodology  for  the IACS  quality assessments  already takes  into 
account  eligibility  conditions  that  can  be  verified  via  administrative 
checks, excluding them from the quality assessment exercise. 

The  correctness  of  data  provided  for  indicators  is  fundamental  to  the 
performance-based approach of the new delivery model. Hence there is a 
need  for  its  assessment.  Following  its  commitments  within  the 
simplification package, the Commission revised the AMS methodology, 
allowing  a  reduction  of  the  control  burden  under  the  AMS  quality 
assessment. The Commission encourages Member States not to run two 
parallel systems but to use the AMS and its preventive character as much 
as possible. However, this depends on how Member States have designed 
their intervention and their control system.  

DE 

DE 

ES 

FI 

COPA-
COGECA 

53 

 
 
 
 
65 

66 

67 

68 

69 

70 

Suggestions 

Proponents 

Assessment 

Controls and penalties 

Simplification: optimise control and monitoring procedures to 
reduce  the  burden  on  farmers,  and  to  make  them  more 
proportionate. 

CZ, FR, BE, 

COPA-
COGECA 

Actions  taken  within  the  simplification  package  will  help  reduce  the 
control burden. Member States already have leeway to optimise controls 
and monitoring. 

Simplification:  request  to  simplify  the  sanctions/penalty 
system (esp. for those that are 100% monitorable). 

Flexibility: greater leeway for Member States in setting controls 
and  penalties  (including  for  conditionality).  Greater  focus  on 
risk-based  controls  (Articles  83  to  89  of  the  Horizontal 
Regulation). 

Right of error: extend the ‘right of error’ approach to animal-
based interventions (Article 7(2) of Commission Implementing 
Regulation (EU) 2022/1173). 

Right of error: allow the application of the right to error up to 
the  dates  defined  according  to  the  different  payment  dates  of 
each type of aid, and not according to a single date (Article 7(2) 
of  Commission  Implementing  Regulation  (EU)  2022/1173). 
Establish a right to error for new rules given the complexity of 
regulations, successive changes and late communications. 

Allow for a margin of error in complying with conditionality 
rules, particularly in the first years of application or when faced 
with  exceptional  circumstances.  Give  farmers  and  public 
authorities time to adapt to the new specificities of the rules and 
give leeway to face exceptional circumstances. 

CY 

SE,  

COM AGRI 

The design of controls and  the  penalty system is up to Member States. 
Monitorable interventions should prevent later penalties.  

Under the new delivery model of the CAP, Member States are authorised 
to  fix  their  own  control  systems,  except  for  controls  related  to 
conditionality. Member States must establish the control sample for the 
on-the-spot checks to be carried out each year based on a risk analysis. 

SE 

Addressing this issue is already possible within the current EU CAP 
framework. 

FR, HU 

ECVC 

Addressing  this  issue  is  already  possible  within  the  current  EU  CAP 
framework. The Commission organised a workshop to support Member 
States in rationalising their control set-up and allows farmers to correct 
their applications where mistakes were made or adjust it based on realities 
on the ground.  

The simplification package clarifies the EU CAP framework as regards a 
‘right  of  error’,  as  well  as  possibilities  for  farmers  to  correct  their 
application later in the year when using the AMS. The Commission also 
proposed  additional  flexibility  to  enable  Member  States  to  establish 
specific exemptions from the requirements of GAEC standards 5, 6, 7 or 
9 (see the adopted Simplification Regulation) and clarified the conditions 

CEJA 

54 

 
 
 
 
Suggestions 

Proponents 

Assessment 

71 

Warning system: stop immediate sanctions for administrative 
failings but launch a warning system. 

ECVC 

A warning system is already allowed under the EU CAP framework. It is 
for Member States to introduce such a system. 

for  use  of  force  majeure  and  the  exceptional  circumstances  clause 
(COM(2024)225 final).  

72 

Exceptional circumstances: clarification requested on the type 
of exemptions from penalties that can be justified by exceptional 
circumstances  (Articles 3, 59 and 84(2)(c)(i) of the Horizontal 
Regulation). 

SE 

73 

Scope:  request  not  to  apply  controls  and  penalties/sanctions 
below a threshold for subsidies or for small farms. 

CY 

74 

Scope: limit the control of animal numbers only to aid coupled 
to animal production. 

EL, FR 

Article 3 of the Horizontal Regulation lists all the exceptions in case of 
force majeure and exceptional circumstances. Sanctions do not apply on 
payments and conditionality in cases of exceptional circumstances. There 
is an exception for social conditionality: only cases of force majeure (not 
exceptional  circumstances)  can  be  exempted  from  sanctions  (Article 
88(2)(b)(i)  of  the  Horizontal  Regulation).  Within  the  simplification 
package, on 30 May 2024, the Commission adopted a Communication to 
the  Council  on  force  majeure  and  exceptional  circumstances  in  the 
Horizontal  Regulation,  which  clarifies  the  application  of  this  concept 
(COM(2024)225 final).  

The design of the control and penalty system is up to Member States. As 
part of the simplification package the Commission proposed to amend the 
Horizontal Regulation to remove conditionality controls and penalties for 
small farmers  (below  10  hectares  of agricultural  area)  (see the  adopted 
Simplification Regulation). 

It is in principle up to Member States to decide on their eligibility control 
rate, however the controls cannot be limited only to a single intervention. 
As regards conditionality, the control sample is set at 1% of beneficiaries. 
In any case, the whole farm approach (all parcels and premises are to be 
controlled on all conditionality obligations and all payments together will 
be affected if penalties are applied) applies in order to be a deterrent and 
proportionate. As from 2023, the identification and registration of animals 
is not within the scope conditionality. 

55 

 
 
Suggestions 

Proponents 

Assessment 

75 

Scope:  exempt  small  farmers  from  conditionality  controls 
(Article 83 of the Horizontal Regulation.) 

ES, RO, SI, 

EL, HR 

This  suggestion  was  addressed  by  the  simplification  package,  which 
includes the  Commission proposal  to  amend  the  Horizontal  Regulation 
(see the adopted Simplification Regulation). 

76 

Scope: exempt communal pastures from controls and penalties 
(Article 83(6)(d)(iii) of the Horizontal Regulation.) 

ES 

The  suggestion  was  not  taken  up.  The  simplification  package  already 
includes a significant simplification by exempting small farmers (<10 ha) 
from the controls and penalties of conditionality. Beyond this, it would 
not be appropriate to exempt certain types of holdings or areas due to the 
ownership  or  user  structure.  Beneficiaries  subject  to  conditionality 
controls and penalties should be included in the population from which 
the 1% sample for controls should be extracted. 

77 

78 

79 

Cross-compliance:  remove  double/parallel  checking  and 
sanctioning  of  farmers  in  cases  where  both  cross  compliance 
(pre-2023) and conditionality rules apply (Article 104 (1) (a) of 
the  Horizontal  Regulation,  and  Article  12  of  Commission 
Delegated Regulation (EU) 2022/1172/EU). 

HU 

This suggestion was addressed by the simplification package. 

Level  of  sanctions:  reduce  conditionality  sanctions,  do  not 
apply  them  in  2024  (Articles  9  to  11  of  the  Horizontal 
Regulation ). 

HU, RO 

remove 

system 
SMRs/GAECs: 
(conditionality  reductions  in  cases  where  fines  have  already 
been imposed in relation to the SMRs), review SMRs to avoid 
double sanctions. 

the  double  penalty 

BE, SE 

56 

The suggestion was not taken up. The reductions of CAP payments linked 
to conditionality controls are already rather limited: 3% of CAP support 
as  a  general  rule,  with  the  possibility  to  reduce  to  1%.  This  means  a 
penalty  of  EUR  30  for  every  EUR  1 000  of  CAP  support.  Further 
reduction of penalties would go against their deterrent effect. 

The  relevant  EU  environment/sanitary  legislation  creates  a  sanctions 
system (fines and other sanctions). The conditionality system under  the 
CSP  Regulation  is  not  a  sanction  system  under  EU  environment  and 
sanitary legislation – it merely provides for a reduction of CAP support in 
case of non-compliance with a limited number of obligations stemming 
from certain acts of EU law.   

 
 
Suggestions 

Proponents 

Assessment 

80 

Reasonableness  of  costs:  to  determine  that  for  non-IACS 
projects  or  costs  under  a  certain  amount  no  verification  of 
reasonableness of costs is needed. 

SI 

81 

82 

83 

84 

On-farm  inspection:  the  use  of  AMS  could  be  beneficial  to 
reduce  on-farm  inspections,  provided  it  delivers  (example  of 
several countries in which the use of AMS Quality Assessment 
has led to a significant increase in on-the-spot checks). 

COPA-
COGECA 

On-farm  inspections:  reduce  on-the-spot-checks  to  one  visit 
per farm per year (Article 60 of the Horizontal Regulation).  

EL, FR 

Hemp: call to reduce minimum on-the-spot control rate of hemp 
varieties from 30% to 10% of areas declared for support Annex 
I of Commission Delegated Regulation (EU) 2022/126. 

Cumulative controls: allow more possibilities for cumulative 
controls under different policies. 

DE 

BE 

57 

The CSP and the Horizontal Regulations no longer provide for rules on 
the  reasonableness  of  costs,  unlike  the  legislation  for  the  previous 
planning  period.  However,  Member  States  have  an  obligation  to  take 
measures to ensure sound financial management and effective protection 
of the EU's financial interests based on Regulation (EU) 2018/1046 on the 
financial rules applicable to the general budget of the Union and Articles 
59(2) and 60(1) of the Horizontal Regulation. It is therefore for Member 
States  to  determine  appropriate  measures  to  comply  with  these 
obligations,  such  as  the  verification  of  the  reasonableness  of  costs  for 
subsidised operations. 

The  AMS  is  an  automated  process  that  does  not  involve  on-the-spot 
checks.  On  the  contrary,  the  more eligibility  conditions  are  covered  by 
AMS,  the  fewer  field  visits  are  needed  to  verify  compliance  with 
eligibility conditions.  

It is up to Member States to set up an efficient control system that ensures 
that outputs are real. For conditionality, current EU CAP rules allow on-
the-spot  checks  to  be  concentrated  in  one  visit.  Since  the  start  of 
conditionality  (cross-compliance  in  2005),  ensuring  synergies  with 
various  control  bodies  is  recommended.  But  if  some  elements  to  be 
controlled depend on a particular season of the year, it might be necessary 
to come back to verify them. 

The suggestion was not taken up. A sufficient rate of controls contributes 
to the verification of the variety cultivated and thus prevent potential cases 
of illegal cultivation of hemp.  

It is for Member States to organise their control system in a way to avoid 
duplication of controls.  

 
 
 
Suggestions 

Proponents 

Assessment 

Intentionality: request to change (conditionality) or withdraw 
the  concept  of  intentionality  from  the  assessment  of  non-
compliance. Apply instead other criteria (severity and impact). 
(Article 85 (1) and (6) of the Horizontal Regulation and Articles 
9  and  10  of  Commission  Delegated  Regulation  (EU) 
2022/1172). 

Intentionality: reduce the percentage of reductions in the case 
of  unintentional  non-compliance 
(Article  9(1)(2)  of 
Commission Delegated Regulation 2022/1172) . 

Penalties:  request  to  increase  the  de  minimis  threshold  from 
EUR 100 to EUR 300 (the threshold from which penalties for 
conditionality  are  applied)  (Article  84(2)b  of  the  Horizontal 
Regulation). 

Period  of  control:  reduce  the  period  of  control  of  livestock 
(from the entire calendar year) to allow advanced payments in a 
shorter time. 

85 

86 

87 

88 

BG, CZ, HU, 
RO 

The  suggestion  was  not  taken  up.  The  notion  of  ‘intentionality’  is 
applicable  only  for  conditionality  (including  social  conditionality). 
Intentionality is a criterion that allows Member States to increase the level 
of  penalties.  It  is  not  compulsory  to  apply  this  in  every  check.  The 
applicable rules for aggregation were already simplified in 2021, bringing 
the reduction from 20% to 15% of the support concerned by conditionality 
as a general rule. 

HR 

This is already possible under the current EU CAP framework. Reductions 
in case of unintentional non-compliance are decided at the national level.  

HR, HU, RO 

Increasing  this  threshold  would  mean  that  a  high  number  of  non-
compliances  with conditionality requirements  would not  be  sanctioned, 
which  would  reduce  the  deterrent  effect  of  the  controls  and  penalties 
system. 

IT 

It is up to the Member States to design their control and penalty systems 
for interventions. Compliance with Articles 59, 60, 72 of the Horizontal 
Regulation must, however, be ensured.  

89 

LEADER: cancelling ex post checks for LEADER (intangible 
investments). 

LU 

The CSP and the Horizontal Regulations no longer provide for rules on ex 
post checks for these interventions, unlike the EU legislation applicable 
in the previous programming period. Member States must take measures 
to  ensure  effective  protection  of  the  EU's  financial  interests  and  set  up 
efficient management and control systems based on Articles 59(1) and (2) 
and  60(1)  of  the  Horizontal  Regulation.  It  is therefore  for  the  Member 
States  to  put  in  place  a  management  and  control  system  that  functions 
properly.  

58 

 
 
Suggestions 

Proponents 

Assessment 

90 

Type of controls: preference should be given to controls based 
on documentation where it offers sufficient guarantees. 

91 

Type of controls: replace/reduce controls related to compliance 
with EU legislation with checks based on available databases.  

FR 

CZ 

92 

Reduce  the  frequency  of  controls  to  address  unintentional 
errors and to provide for the right to error. 

COPA-
COGECA 

It is up to the Member States to design their control and penalty systems 
for  interventions  in  compliance  with  Articles  59,  60  and  72  of  the 
Horizontal Regulation.  

Under the EU CAP framework administrative checks are already possible. 
Further to the simplification package, the Commission will organise  an 
exchange  of  best  practice  with  Member  States  on  how  to  coordinate 
controls and sanctions systems under EU environment, climate and animal 
welfare legislation with checks related to CAP conditionality. 

Under the new delivery model of the CAP, it is up to the Member States 
to  design  their  control  systems,  including  the  number  of  checks,  the 
number of visits and the ways to visit, to get assurance that the amounts 
of aid requested are in line with the applicable legislation. Rationalisation 
of all controls on the farm is for the Member States to look into. 

Avoid  gold-plating:  with  the  burden  of  control  shifted  to 
fines,  many  national 
to  avoid 
Member  States  and 
administrations introduce gold-plating requirements, leading to 
more severe fines. It is important to take stock of the national 
control  systems  to  identify  simple,  efficient,  and  proportional 
methods.  Proactive 
individualised  communications  with 
farmers  in  advance  of  action  deadlines  to  minimise  non-
compliance  and/or  associated  appeals/penalties  etc. 
is 
necessary. 

Reduce controls and sanctions: stop the policy of over-control 
and  sanctions,  particularly  for  those  who  engage  in  agri-
environmental measures. It is proposed that there should be no 
baseline  checks  on  eco-schemes  or  cumulative  sanctions  for 
previously unreported errors. 

93 

94 

COPA-
COGECA 

Avoiding  ‘gold-plating’  (additional  rules  and  regulatory  obligations)  is 
the responsibility of the Member State.  

As to controls, the design of the control system is the responsibility of the 
Member State. The Commission encourages Members States to exchange 
best practice on this, including through the CAP Network. 

ECVC 

A farmer who has taken up commitments under an eco-scheme must also 
comply  with  conditionality  and  other  baseline  requirements  for  that 
intervention. Under the  new delivery  model of the CAP, it is up to the 
Member  States  to  design  the  control  system  for  such  interventions, 
including the number of checks, number of visits, ways to visit, and how 

59 

 
 
Suggestions 

Proponents 

Assessment 

to  obtain  assurance  that  the  amounts  requested  for  aid  are  legal  and 
regular. Rationalisation of all the controls on a farm is a Member State’s 
responsibility. The Commission engages with Member States to support 
rationalisation of their controls, as indicated in the simplification package. 

It is up to the Member States to design their control systems, including 
checklists. As announced in the simplification package, the Commission 
engages with Member States to support rationalisation of controls. 

Controls are financed outside the operational CAP budget. Administrative 
costs for implementation and control of the CAP in the Member States are 
borne by national and regional administrations. Costs of controls by EU 
officials do not weigh on the operational CAP budget. 

The  EU  CAP  framework  already  provides  Member  States  with  the 
flexibility  to  set  their  own  control  systems,  including  decisions  on  the 
required  documentation  and  on  arrangements  to  seek  synergies  based 
within their national systems in providing documentation and controls. 

The EU CAP framework provides Member States with the flexibility to 
design  control 
required 
documentation. 

including  decisions  on 

systems, 

the 

This suggestion was not taken up. This information is essential in the GSA 
for  certain  interventions  e.g.  to  assess  the  effectiveness  of  the 
interventions  for  the  sustainable  and  reduced  use  of  plant  protection 
products 
climate-related 
commitments). 

environmental 

(eco-schemes 

and 

and 

95 

96 

97 

98 

99 

Review the checklist of controls as it is too broad in certain 
cases. 

ECVC 

Financing of controls: controls must be paid for by a dedicated 
European Union fund outside the CAP. 

ECVC 

Documentation: reduce documentation requirements to prove 
compliance  with  the  CAP  rules.  Clarify  the  conditions  for 
implementing  the  principle  of  proportionality  for  controls 
(documentation). 

Documentation: provide EU-level rules in relation to proving 
the (legal) disposition of the agricultural land to avoid duplicate 
declaration of areas. 

Documentation:  information  on  the  use  of  plant  protection 
products  for  parcels  under  interventions  for  sustainable  and 
reduced use of pesticides should not be a compulsory element 
of  the  geo-spatial  application  (GSAA).  (Article  8  (3)  of 
Commission Implementing Regulation (EU) 2022/1173). 

AT, EL 

SK 

HU, BE 

60 

 
 
 
 
Suggestions 

Proponents 

Assessment 

Performance and reporting 

100 

Simplification  of  monitoring:  need  for  simplification  of  the 
monitoring  and  reporting  approach  (contents  of  the  annual 
performance report, indicators, reporting on performance, table 
of indicators, unit amount logic, action plans and justification). 

CY 

Monitoring is essential in a performance-oriented policy, such as the new 
delivery model of the CAP. It allows the Commission to evaluate whether 
the planned results have been achieved. Lessons learned from the current 
period will feed into the reflection on the post-2027 CAP. 

101 

Ex  ante  assessment:  remove  the  requirement  for  an  ex  ante 
assessment of CAP Plans. 

AT, CY, CZ, 
ES, MT 

Lessons learned from the current period will feed into the reflection on the 
post-2027 CAP.  

102 

Indicators: adjust the methodology of Result Indicator 34 (R.34 
Preserving landscape features: Share of UAA under supported 
commitments  for  managing  landscape  features,  including 
hedgerows  and  trees)  to  include  all  non-productive  and  other 
landscape features and areas. 

HU 

103 

Indicators:  allow  retroactive  modification  of  the  values  of 
relevant indicators in the case of amendment of CAP Plans.  

BG 

With the simplification package, the Commission adjusted the monitoring 
and  evaluation  legislation (Commission  Implementing  Regulation (EU) 
2024/1962  amending  Implementing  Regulation  (EU)  2022/1475). 
Member  States  will  report  hectares  of  arable  land  paid  for  maintaining 
non-productive  areas,  such  as  land  lying  fallow,  including  landscape 
features, under variable M101. This new variable will address the concern 
raised,  while  indicator  R.34  will  allow  the  monitoring  of  all  landscape 
features under maintenance, whether on arable land, permanent cropland, 
grassland or other eligible area. The scope of R.34, included in the label 
of the indicator, cannot be changed  by implementing regulation as it is 
defined in Annex I to the CSP Regulation. 

Retroactive  amendments  of  CAP  Plans  related  to  the  EAGF  would  in 
principle not  be in line  with  Article  119(8), third subparagraph,  of the 
CSP  Regulation.  Retroactive  amendments  of  values  under  result 
indicators  would  have  a  significant  impact  on  the  functioning  of  the 
performance framework for the CAP Plans. Such amendments would also 
go  against  the  calls  from  farmers  for  a  greater  stability  of  CAP 
implementation.  

61 

 
 
Suggestions 

Proponents 

Assessment 

104 

Indicators: reduce the number of categories of indicators.  

AT 

105 

Indicators: revise the methodology of calculation of beehives 
indicators (double counting). 

ES 

106  Reporting: reduce reporting requirements. 

CZ, IE 

107 

Reporting:  unify  reporting  obligations  (types,  deadlines)  for 
monitoring and evaluation 

CZ 

108 

Performance  reviews:  simplify 
the  biannual 
performance reviews (not two, but only one for 2026) or to align 
the  timing  with  the  mid-term  review  required  for  funds  other 
than CAP (Article 135(1) of the CSP Regulation). 

/  reduce 

BG, CZ, EL, 
LT, HU, MT, 
RO, SI 

109 

Targets/deviation:  call  to  change  the  acceptable  rate  of 
deviation  from  the  milestones  from  25%  to  40%  for  2026 
(Article 135(2) of the CSP Regulation). 

CZ, BG, EL, 

SI, HU, RO 

The suggestion was not taken up. The indicators are a cornerstone of the 
new delivery model of the CAP and its performance-based approach. Each 
category of indicators has a specific purpose, be it assurance, performance 
review, monitoring or evaluation of the performance of the policy. 

The  calculation  method  of  aggregated  values  for  the  indicator  O.37 
(apiculture)  was  simplified.  R.35  (Share  of  beehives  supported  by  the 
CAP) covers only the support granted directly to beekeepers, allowing the 
double counting of beehives to be eliminated.  

The Commission is rolling out a wide range of actions to reduce reporting 
obligations in all policies, including the CAP. Lessons learned from the 
current period will feed into the reflection on the post-2027 CAP. 

Under Commission Implementing Regulation (EU) 2022/1475, dates and 
ways  to  report  have  been  simplified  as  much  as  possible.  Dates  were 
adapted to Member States’ requests, while ensuring the availability of data 
for monitoring and evaluation. 

The suggestion was not taken up. Two biennial performance reviews are 
planned  for  financial  years  2024  and  2026,  respectively.  Limiting  the 
number  of  performance  reviews  further  to  one  review  only  would 
undermine  the  new  delivery  model  of  the  CAP  2023-2027  and  its 
performance-based  approach.  Lessons  learned  from  the  current  period 
will feed into the reflection on the post-2027 CAP. 

The suggestion was not taken up. Increasing the shortfall rates referred to 
in  Article  135(2)  of  the  CSP  Regulation  would  undermine  the  new 
delivery  model  of  the  CAP  2023-2027  and  its  performance-based 
approach. 

62 

 
 
Suggestions 

Proponents 

Assessment 

111 

112 

110 

APR:  simplify  the  process  and/or  content  of  the  annual 
performance  report  (APR)  (Article  54  of  the  Horizontal 
Regulation). 

AT, CY, SI 

APR  deadline:  postpone  the  15  February  deadline  for 
submitting the annual performance report to allow the necessary 
collection and processing of data (Article 9(3) of the Horizontal 
Regulation). 

CZ, DK, EL, 
ES, SI 

The Commission has reviewed the APR template and the relevant parts of 
the  IT module (SFC  2021)  used  for  the submission  of  the  APRs. Most 
changes  were  implemented  in  SFC2021  at  the  end  of  July  2024  for 
reporting  for  financial  year  2024,  to  be  submitted  in  2025,  with  the 
remaining changes scheduled for September 2024. 

The suggestion was not taken up. The EU CAP legislation already offers 
Member  States  the  possibility  to  request  an  extension  of  this  deadline. 
However,  the  APR  has  to  be  submitted  to  the  Commission  within  the 
applicable  deadlines,  to  ensure  the  timely  completion  of  the  annual 
performance clearance and biennial performance review. Member States 
need to arrange an efficient exchange of information between the national 
bodies involved and adequate IT solutions.  

APR/aggregate  values:  request to  abolish  the  requirement  to 
provide  in  the  APR  the  aggregate  values  of  realised  outputs. 
Simplify rules on double counting (Section 2.3 of the Annex to 
Implementing Regulation 2023/130 on the content of the APR). 

ES, IE 

The  suggestion  was  not  taken  up.  The  aggregated  values  of  realised 
outputs are fundamental for monitoring, communication, and evaluation.  

The  suggestion  was  not  taken  up.  Member  States  need  to  report  in  the 
APR what outputs were reached with the expenditure paid in the given 
financial year, as this is a key element of the new delivery model of the 
CAP.  

The  suggestion  was  not  taken  up.  This  data  is  key  for  monitoring  and 
evaluation  of  the  CAP  and  CAP  plans  under  the  performance-based 
approach. Besides, the data is already available in the paying agencies. 

113 

APR/outputs: abolish reporting of partial output by financing 
year. 

114 

Individual  data:  request  to  remove  a  requirement  to  provide 
disaggregated data at the level of interventions and beneficiaries 
(Commission Implementing Regulation 2022/1475). 

LV 

ES 

63 

 
 
 
 
Suggestions 

Proponents 

Assessment 

Assurance, annual performance clearance, and audits 

The suggestions were not taken up. EU funds may not finance expenditure 
which was not effected in conformity with EU law. Member States must 
ensure  that  payments  to  farmers  are  legal  and  regular.  This  entails 
compliance with all elements of the approved CAP Plans, as laid down in 
the EU CAP legislation.  

The focus on realisation of policy goals (‘performance’) is an objective 
that the Commission fully shares with the Member States. For this reason, 
lessons learned from the current period will feed into the reflection on the 
post-2027 CAP.  

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. Removal of such controls would need to be weighed 
against their deterrent effect. 

Extensive  discussions  on  financial  corrections  and  serious  deficiencies 
took place in the context of the preparation of new guidelines on financial 
corrections. The proposal to apply financial corrections above a certain 
threshold  was  introduced  in  the  guidelines  on  financial  corrections 
(document C/2024/5991), where the functioning of the Member States’ 
systems  is  concerned.  It  was  explained  that  the  level  of  this  threshold 
should  be  the  materiality  level  for  all  EU  funds,  as  accepted  by  the 
discharge authority.  

The  criteria  for  efficient  management  and  control  systems  have  been 
discussed and set together with the Member States and will be assessed 
by the certification bodies. 

115 

Scope:  requests  to  limit  assurance/conformity  procedures 
(‘potentially  serious  deficiencies’  or  expenditure  outside  the 
CSP, focus on realisation of policy goals rather than legality of 
spending) (Article 55 of the Horizontal Regulation). 

AT, FR, NL, 
HU 

116 

Scope:  remove  the  controls  on  operations  provided  for  in 
Chapter III of Title IV of the Horizontal Regulation. (Scrutiny 
of transactions of the system of financing by the EAGF.)  

117 

Financial  corrections:  financial  corrections  to  apply  above  a 
certain budgetary risk rate for the EU agricultural funds (5% and 
with possibilities for quantifying this risk). 

118 

Control  mechanism:  the  criteria  of  ‘efficient  Member  State 
control  mechanisms’  should  be  defined  in  a  way  that  the 
resource  needs  of  compliance  should  be  proportionate  to  the 
financial risk (Articles 59 and 60 of the Horizontal Regulation).  

FR 

FR 

HU 

64 

 
 
Suggestions 

Proponents 

Assessment 

Certification bodies: we invite the Commission to review and 
revise the  content of guidelines for certification bodies (GL3) 
and reduce the required amount of information to the minimum 
necessary.  For  audit  objective  2,  the  Commission  is  asked  to 
consider  the  level  of  granularity  of  the  information  needed 
regarding  the  sample  size  and  the  sampling  approach  per 
intervention. 

(Articles 9 and 51 of Regulation (EU) 1306/2013, Articles 5 to 
7 and 29 to 33 of Commission Implementing Regulation (EU) 
908/2014, Articles 12, 53 and 54 of the Horizontal Regulation, 
Articles  5  to  7  and  32  to  36  of  Commission  Implementing 
Regulation (EU) 2022/128) 

APR/justification  and  unit  amount: 
simplify  data/ 
justification requirements for the annual performance clearance 
and/or remove the potential financial consequences for Member 
States if the realised unit amount of an intervention exceeds the 
planned  unit  amount.  (Article  134(6)  (a)  and  (b)  of  the  CSP 
Regulation). 

119 

120 

HU 

The feasibility and the impact of the proposal is under examination and 
GL3 for certification bodies will be updated by autumn 2024.    

HU, SI 

Based on the first annual performance clearance, there has been discussion 
with the Member States on the lessons learned in the Expert Group for 
Horizontal Questions concerning the CAP and the possible ways forward 
to  streamline the exercise in  the future.  Several  options  to simplify  the 
exercise were contemplated, one of which is introduction of a de minimis 
for  justifying  deviations  from  planned  unit  amounts  for  the  annual 
performance clearance. Further steps as regards the annual performance 
clearance exercise will be considered. 

65 

 
 
 
 
II. CAP STRATEGIC PLANS – THE GREEN ARCHITECTURE 

Suggestions 

Proponents 

Assessment 

Contributions to targets set in the environment and climate legislation set out in Annex XIII of the CSP Regulation 
(Article 120 of the CSP Regulation) 

121 

Article 120 of the CSP Regulation: removal of this article that 
requires  a  review  of  CAP  Plans  in  light  of  changes  to  the  EU 
legislation in the areas of (mainly) environment and climate. 

BG, CZ, LV, 
PT, BE 

122 

Details for Article 120 assessment: too much detail and lack of 
clarity on the follow-up to the assessment required from Member 
States. . 

LV 

Partially addressed by the Commission proposal, which was part of the 
simplification package, limiting the application of Article 120 of the CSP 
Regulation to amendments of these EU legislative acts that enter into force 
before 1 January 2026 (see also the adopted Simplification Regulation). 

Partially  addressed  by  the  Commission  proposal  that  was  part  of  the 
simplification package, which limits the application of Article 120 of the 
CSP Regulation to acts that enter into force before 1 January 2026 (see 
also  the  adopted  Simplification  Regulation).  Should  any  further 
notification under this Article be due before that date, the procedure will 
be clarified in advance. 

CAP Strategic Plan – Conditionality 

123 

Level of detail:  CAP Plans should only contain a ‘summary of 
the on-farm practice’ for each GAEC standard. 

DK 

Lessons  learned  from  the  current  period  will  feed  the  reflection  on  the 
post-2027 CAP. 

66 

 
 
 
 
Suggestions 

Proponents 

Assessment 

124 

Overlap  between  GAEC  standards  requirements:  avoid 
overlaps  between  GAEC  standards  requirements.  Reduce  the 
number of standards that relate to partly redundant requirements, 
for example GAEC 1 and 9 or even 2 (preservation of grasslands) 
as well as GAEC 6, 7 and 8 (soil conservation).  

FR 

The  suggestion  was  not  taken  up.  Each  GAEC  standard  has  a  specific 
main objective and scope laid down in Annex III to the CSP Regulation. 
It  is  the  responsibility  of  Member  States  to  ensure  a  clear  articulation 
between the requirements of the different GAEC standards. 

The  suggestion  was  not  taken  up.  This  proposal  would  hamper  the 
achievement  of  the  policy  objectives  of  the  CAP  in  2023-2027. 
Conditionality is a key part of the higher environmental ambition of this 
CAP compared to the previous one. The combination of a higher baseline 
through conditionality with enhanced funding for eco-schemes is at the 
heart of the ‘green architecture’ of the CAP 2023-2027. 

Addressed  by  the  Commission  proposal  as  a  part  of  the  simplification 
package, as regards the first requirement of GAEC 8 (see also the adopted 
Simplification Regulation). 

The suggestion was not taken up. Conditionality is the basis for all area-
based  payments.  This  proposal  would  hamper  the  achievement  of  the 
policy objectives of the CAP in 2023-2027.  

Article  13  of  the  CSP  Regulation  already  provides  that  Member  States 
should  take  into  account,  where  relevant,  specific  soil  and  climatic 
conditions, farming systems and practices and land use when setting their 
GAEC  standards.  The  Commission  proposal  which  is  part  of  the 
simplification package provides Member States with additional flexibility 
in setting GAEC standards and additional possibilities to provide targeted 

125 

Eco-schemes  instead  of  conditionality:  turn  requirements 
related to GAEC standards (other than GAEC standard 8) into 
eco-schemes. 

CZ, BE, EE, 
PT, SI, SK 

126 

Make  GAEC  8  an  eco-scheme:  turn  requirements  related  to 
GAEC standard 8 into eco-schemes. 

BE, CZ, PL, 
EE, SI, DK 

127 

Make  GAEC  agri-environment-climate  measures (AECM): 
exclude  hectares  under  AECM  from  conditionality  /  replace 
GAEC standards by AECM. 

128 

Flexibility: allow for GAEC exemptions, and flexibility, taking 
into  account  Member  State  specificities  and  farming  systems 
and/or following extreme climatic events.  

DK, SI 

BE, CY, DE, 
DK, ES, IE, 
LU, LV, RO, 
MT 

COPA-
COGECA, 

67 

 
 
Suggestions 

Proponents 

Assessment 

exemptions as well as temporary derogations for weather-related reasons 
(see also the adopted Simplification Regulation).   
As  regards  GAEC  6  and  7,  the  suggestion  was  addressed  by  the 
Commission  proposal  that  is  part  of  the  simplification  package.  For 
GAEC  8,  the  Commission  proposal  entails  deletion  of  the  first 
requirement from Annex III to the CSP Regulation. See also the adopted 
Simplification Regulation. 

Full derogations from GAEC standards would hamper the achievement of 
the policy objectives of the 2023-2027 CAP. However, the simplification 
package introduces the possibility for Member States to grant temporary 
and  targeted  derogations  from  requirements  of  GAEC  standards  where 
weather  conditions  prevent  farmers  and  other  beneficiaries  from 
complying  with  those  requirements  in  a  given  year.  See  the  adopted 
Simplification Regulation. 

The  suggestion  was  partially  addressed,  as  under  the  Commission 
proposal  that  is  part  of  the  simplification  package,  small  farmers  are 
exempt from conditionality controls and penalties. See also the adopted 
Simplification Regulation. 

Where relevant, organic farmers could also benefit from the new targeted 
exemptions (simplification package) from GAEC 5, 6 and 9, provided that 
the Member State setting such exemptions in its CSP complies with the 
conditions of Article 13 of the CSP Regulation. Given the amendments to 
the CSP Regulation brought as a part of the simplification package, the 

129 

Flexibility: substantial revision of GAEC 6, GAEC 7, GAEC 8 
to  accommodate  the  practical  possibilities  of  fulfilling  the 
into 
enhanced  conditionalities  by 
consideration the national specificities from the geographical and 
meteorological point of view. 

farmers  and 

taking 

130 

Derogations: allow derogations from the GAECs (full or limited 
in time)  

131  Exemptions: exemption from GAEC standards for small farmers 

ECVC 

RO, SK,  

COM AGRI 

SI, EL, BG, 
CZ, HU, HR, 
SI, IT 

COPA-
COGECA 

BG, CY, EE, 
ES, HU, MT, 
SI 

132 

Exemptions: organic farmers should be deemed compliant with 
GAEC standards (other than GAEC standard 7).  

ES, DE, SE 

IFOAM 

68 

 
 
 
Suggestions 

Proponents 

Assessment 

request to exempt organic farmers from GAEC 8, first requirement is no 
longer relevant. 

The  Commission  is  carrying  out  two  complementary  studies  that  will 
assess  the  costs  for  farmers  of  environmentally  sustainable  farming 
practices, including those that are part of conditionality requirements. The 
first  study  will  look  into  the  economics  of  the  adoption  of  agro-
environmental practices, while the second one will assess what motivates 
farmers  to  decide  to  change  their  farming  practices  and  possibly  their 
production systems and the role and effectiveness of policy instruments 
in supporting such a transition. 

The suggestion was addressed by the amendment of Delegated Regulation 
(EU) 2022/126 under the simplification package. 

The  amendment  of  Delegated  Regulation  (EU)  2022/126  under  the 
simplification package brought additional flexibility in the calculation of 
the 2018 reference ratio in case of structural changes to farming systems 
resulting in a reduction of permanent grassland area, as well as changes in 
the 
the 
implementation  of  GAEC  1  must  respect  the  definition  of  permanent 
grassland set by Member States in their CAP Plans, in accordance with 
Regulation (EU) 2021/2115. 

reconversion  obligations.  However, 

rules  concerning 

133 

Costs: assess the conditionality requirements when it comes to 
their impact on the cost and burden for farmers. 

COPA-
COGECA 

134 

GAEC1:  revision  of  GAEC  1  rules  on  the  calculation  of  the 
permanent grassland ratio.  

FR, LT 

COPA-
COGECA 

135 

GAEC 1: modification of the rules for the calculation of ratios 
to replace the admissible surface area by the graphic surface area.  

FR 

69 

 
 
 
Suggestions 

Proponents 

Assessment 

136 

GAEC  1:  enable  Member  States  to  revise  the  scale  used  for 
calculating  the  ratio  if  they  choose  to  do  so,  including  during 
programming  (for  example  to  move  from  a  calculation  at  the 
farm  level  to  a  calculation  at  the  regional  level,  or  from  a 
calculation at the regional level to a calculation at the national 
level).  This 
type  of  modification  should  be  applicable 
immediately.  

137 

GAEC  2:  in  the  absence  of  an  EU  definition  of  wetlands,  the 
validation  of  the  CSP  by  the  Commission  must  respect  strict 
regulatory requirements, without disproportionate requirements 
on the nature of the expected measures. 

FR 

FR 

The level at which the ratio of permanent grassland is calculated is set by 
Member States in the CSP. It can be modified subject to the applicable 
procedures and rules  for  amending  CAP  Plans  (Article  119  of the  CSP 
Regulation and Delegated Regulation (EU) 2023/370). 

It is for the Member States to ensure accurate mapping of wetlands and 
peatlands  in  agricultural  areas  for  GAEC  2  purposes.  GAEC  2 
requirements set in the CAP Plans need to be based on such mapping and 
entail the adequate requirements to protect wetlands and peatlands, to be 
in  line  with  the  main  objective  of  that  GAEC  and  to  contribute  to  the 
climate and environmental objectives of the CAP. 

Footnote  1  to  GAEC  2  in  Annex  III  to  the  CSP  Regulation  states  that 
‘Member States, when establishing GAEC standard 2, shall ensure that 
on the land concerned an agricultural activity suitable for qualifying the 
land as agricultural area may be maintained’. The Commission assesses 
the requirements proposed by Member States for GAEC 2 based on this 
requirement,  as  well  as  in  the  light  of  their  contribution  to  the  main 
objective of the GAEC standard and Article 13 of the CSP Regulation. 

138  GAEC 2: postpone the 2025 deadline for its application. 

FR, IE, HU, SI  These  suggestions  were  not  taken  up.  The  possibility  to  delay  the 
implementation of GAEC 2 by 2 years is already provided for by the CSP 

70 

 
 
Suggestions 

Proponents 

Assessment 

Regulation. Further delays would hamper the achievement of the policy 
objectives  of  the  CAP  and  would  undermine  the  level  playing  field 
between Member States, penalising farmers in those Member States that 
introduced the GAEC 2 requirements in compliance with the deadline laid 
down in that Regulation. 

The requirements to be respected by farmers on peatlands and wetlands 
are set by the Member States as a part of GAEC 2 in their CAP  Plans.  
Footnote  1  to  GAEC  2  in  Annex  III  to  the  CSP  Regulation  states  that 
‘Member States, when establishing GAEC standard 2, shall ensure that 
on the land concerned an agricultural activity suitable for qualifying the 
land as agricultural area may be maintained’. The Commission assesses 
the requirements proposed by Member States for GAEC 2 based on this 
requirement,  as  well  as  in  the  light  of  their  contribution  to  the  main 
objective of the GAEC standard and Article 13 of the CSP Regulation. 

Each  GAEC  standard  has  a  specific  main  objective  and  scope.  It  is 
Member States’ responsibility to avoid overlapping requirements and to 
design the  requirements so as to ensure that they are in line with those 
main objectives. 

The suggestion was not taken up as this would hamper the achievement 
of the policy objectives of the CAP 2023-2027.  

Annex III to the CSP Regulation sets the minimum requirements for the 
buffer strips under GAEC 4 with a view to ensuring the contribution to 
the main objective of the standard. GAEC 4 as laid down in Annex III to 

139 

GAEC  2:  more  legal  reliability  for  farmers  in  Member  States 
with  a  staged  approach  for  its  implementation.  Changing  the 
rules during a CAP-period introduces a lot of misunderstanding 
and  extra  complexity  for  the  farmers. Exemptions  based  on 
Article 148 of the CSP Regulation.  

BE 

140 

GAEC  2:  avoid  overinterpretation  of  the  regulation  (ban  on 
ploughing peatland). 

FR, LT 

141 

GAEC 2: monitor the implementation of GAEC 2 to take into 
consideration the impact, at farm level, on the implementation of 
GAEC 7 and GAEC 8. 

COPA-
COGECA 

142  GAEC4: request for this GAEC to be removed.  

143 

GAEC 4: more flexibility regarding the required limits by taking 
into account field sizes and different types of water bodies. 

LU 

LV 

71 

 
 
Suggestions 

Proponents 

Assessment 

the mentioned Regulation already provides some degree of flexibility in 
the requirements for the buffer strips. 

144 

GAEC  4:  flexibility  in  the  rules  of  Plant  Protection  Product 
(PPP)-free  buffer  strips,  revision  of  the  scope  (water  bodies 
definition). 

LV, BE 

The suggestion was not taken up, as it would hamper the achievement of 
the policy objectives of the CAP 2023-2027.  

145 

GAEC 6: changes to sensitive period, allowed practices, scope, 
arid area exclusion. 

146 

GAEC 6: targeted only at areas where water and wind erosion 
occur (not the entire country). 

147  GAEC 7: elimination of GAEC 7. 

Partially addressed by the Commission proposal under the simplification 
package.  Member  States  were  given  further  flexibility  to  define  key 
elements  of  the  GAEC  6,  including the ‘sensitive  period’.  See  also the 
adopted Simplification Regulation. 

The suggestion was not taken up. The changes to the sensitive period and 
the new possibility to set exemptions in the CAP Plans introduced by the 
Commission  proposal  within 
the  simplification  package  provide 
considerable  flexibility  to  Member  States  (see  also  the  adopted 
Simplification  Regulation).  Soil  protection  is  required  on  all  soils,  in 
particular to build up soil organic matter or to prevent its losses. 

The proposal was not taken up as it would hamper the achievement of the 
policy objectives of the CAP 2023-2027.  

AT, ES, PL, 
MT, BE, BG 

COPA-
COGECA, 

CEJA, ECVC 

PL 

IT 

72 

 
 
Suggestions 

Proponents 

Assessment 

148 

GAEC  7:  exempting  regions  with  a  low  share  of  arable  land, 
changing period for secondary crops. 

BE, ES, PL, 
PT, SE, SK 

149  GAEC 7: allow for crop diversification instead of crop rotation. 

BE, IE 

COPA-
COGECA 

150 

GAEC 7: Member States should be allowed to adjust the annual 
crop  diversification  commitments  and/or  annual  crop  rotation 
cycle commitments due to weather circumstances. 

IE 

151 

GAEC  8:  continuation  of  the  2024  GAEC  8  derogation, 
modification  of  the  minimum  share  of  arable  land  devoted  to 
non-productive areas and features.  

BE, FR, HU, 
IT, RO 

COPA-
COGECA 

The suggestion to exempt certain regions from GAEC 7 was not taken up 
in the Commission proposal but the amendments of the CSP Regulation 
brought by the simplification package allow Member States, under certain 
conditions, to set targeted exemptions from certain requirements of certain 
GAEC standards where farmers have specific problems in respecting the 
requirements.  See also the adopted Simplification Regulation   

The suggestion was addressed within the simplification package. See the 
adopted Simplification Regulation. 

The  suggestion  was  not  taken  up,  as  such.  However,  the  simplification 
package includes an amendment of GAEC 7, enabling Member States to 
add  crop  diversification  to  the  CAP  Plans,  enabling  farmers  to  choose 
whether they comply with GAEC 7 though crop diversification or crop 
rotation.  The  Commission  proposal  also  includes  the  amendment  of 
Article 13 of the CSP Regulation, which enables Member States to grant 
temporary  and  targeted  derogations  from  GAEC  requirements  where 
weather  conditions  prevent  farmers  and  other  beneficiaries  from 
complying with those requirements in a given year. See also the adopted 
Simplification Regulation. 

The suggestion was addressed within the simplification package. See also 
the adopted Simplification Regulation. 

73 

 
 
Suggestions 

Proponents 

Assessment 

152 

land  under  AEC  commitments  with 
GAEC  8:  arable 
management obligations or with obligations to cease production 
should  be  excluded  from  the  calculation  of  GAEC  8  of  arable 
land 

DK 

The  suggestion  was  not  taken  up,  in  view  of  the  deletion  of  the  first 
requirement  from  GAEC  standard  8,  proposed  as  a  part  of  the 
simplification package. See also the adopted Simplification Regulation. 

153 

GAEC 8: suggestions for various adjustments (derogations for 
irrigated land, landscape feature retention, conservation grazing, 
greenhouses, etc.).  

DE, ES, BG, 
HU, DK, IE 

The suggestion was partially addressed in the simplification package. The 
requirement to devote a minimum share of arable land to non-productive 
areas or features is removed from GAEC 8, as laid down in Annex III to 
the  CSP  Regulation.  The  requirement  to  retain  landscape  features  on 
agricultural  areas,  which  is  part  of  GAEC  8,  has  not  been  modified. 
Instead, Member States are required to establish an eco-scheme to support 
farmers in keeping non-productive areas, including land lying fallow, and 
establishing new landscape features, on arable land. See also the adopted 
Simplification Regulation. 

154 

GAEC 8: long-term recourse to the alternative proposed by the 
Commission for the 2024 campaign. Compliance reached, with 
at  least  4%  of  farms  utilised  agricultural  area  with  non-
productive elements through nitrogen-fixing crops or catch crops 
without the use of phytosanitary products.  

155 

GAEC  9:  requests  to  allow  greater  management  flexibility 
(allow conversion to EAFRD-supported afforested land, ad hoc 
interventions, rotation, diversification). 

FR 

The  suggestion  was  not  taken  up  in  view  of  the  deletion  of  the  first 
requirement  from  GAEC  standard  8,  proposed  as  a  part  of  the 
simplification package. See also the adopted Simplification Regulation. 

HU, FR, BE 

The suggestion was not taken up as it would hamper the achievement of 
the policy objectives of the CAP 2023-2027.  

74 

 
 
Suggestions 

Proponents 

Assessment 

The  suggestion  was  partially  addressed  in  the  simplification  package. 
Changes to Article 13 of the CSP Regulation brought by the Commission 
proposal  of  15 March 2024  provide  for  the  possibility  to  set  out in the 
CAP Plan exemptions from this standard, in particular if interventions are 
needed  to  address  damage  caused  to  these  environmentally  sensitive 
grasslands  by  wildlife  or  by  invasive  species.    See  also  the  adopted 
Simplification Regulation. 

The suggestion was not taken up, as it would hamper the achievement of 
the policy objectives of the CAP 2023-2027. 

The suggestion was not taken up, as it would hamper the achievement of 
the policy objectives of the CAP 2023-2027.  

The suggestion was not taken up, as it would hamper the achievement of 
the policy objectives of the CAP 2023-2027.  

156 

GAEC 9: authorise flexibilities so that Member States can allow 
the  use  of  one-off  management  interventions  on  permanent 
grasslands designated as sensitive. 

SMR 1: exclusion from SMR 1 of the part related to Article 11, 
part  3,  point  (h)  as  regards  mandatory  requirements to  control 
diffuse  sources  of  pollution  by  phosphates  of  Directive 
2000/60/EC,  because  phosphate  pollution  in  agriculture  can 
result from using manure, mineral fertilisers, and plant protection 
products. 
SMR 3 requirements must only apply to the protection of birds 
inside protected areas and not outside these areas. 

SMR 8: exclude from SMR 8 the part related to Article 13, part 
3 of Directive 2009/128/EC, because the size and structures of 
the  plant  protection  product  storage  are  not  related  to  the 
agricultural activity. 

157 

158 

159 

FR 

LT 

LT 

LT 

75 

 
 
 
 
Suggestions 

Proponents 

Assessment 

CAP Strategic Plan Regulation – Other elements of the climate and environmental architecture  

160 

Green  architecture:  adjustment  of  environmental  and  climate 
requirements for interventions under pillar I and pillar II and for 
implementation, 
animal  welfare,  which 
monitoring, and evaluation. 

to  complex 

leads 

161 

Green architecture: more synergy between different components 
of green architecture. 

RO 

BE 

The  suggestion  was  not  taken  up.  The  CSP  Regulation  lays  down  few 
requirements at intervention level, and Member States are responsible for 
designing the commitments/conditions of the interventions. 

Member States have considerable flexibility in designing the intervention 
strategy  of  the  CAP  Plans  so  as  to  ensure  synergies  between  different 
components of the green architecture. Lessons learned from the current 
period will feed into the reflection on the post-2027 CAP. 

162 

Funding:  more  flexibility  for  unspent  funds,  more  flexibility 
between pillars to manage pillar 2 AECM funds and pillar 1 eco-
schemes, prolong the ‘learning period’ for eco-schemes. 

CZ, MT, RO 

Lessons learned from the current period will feed  into the reflection on 
the post-2027 CAP. 

The current EU CAP framework already provides certain possibilities to 
compensate  for  area-specific  disadvantages  imposed  by  certain  EU 
legislation  (Article  72  of  the  CSP  Regulation).  Also,  for  interventions 
based  on  Articles  31  and  70  of  that  Regulation,  Member  States  may 
continue to fund operations for 24 months from the date on which the new 
requirements  became  mandatory  for  farmers.  Lessons  learned  from  the 
current period will feed into the reflection on the post-2027 CAP. 

Articles  31  and  70  of  the  CSP  Regulation  enable  support  for  fulfilling 
national legislation for a period of 24 months from the introduction of the 
national requirement. Lessons learned from the current period will feed 
into the reflection on the post-2027 CAP. 

163  Scope: expand payments for mandatory (national) requirements 

DK, SE 

164 

Scope: allow CAP support for farmers to fulfil national legislation 
that  goes  further  than  the  EU  baseline,  including  on  animal 
welfare.  Look  into  the  possibility  of  supporting  farmers  for 
common practices beneficial to the environment and the climate. 

SE 

76 

 
 
Suggestions 

Proponents 

Assessment 

165 

land:  setting  qualitative 
Extensification  of  agricultural 
restrictions  linked  to  depreciation  of  the land  and  being  able  to 
compensate for that depreciation.  

NL 

Lessons learned from the current period will feed  into the reflection on 
the post-2027 CAP. 

166 

Premiums: the Commission to be more open to eco-schemes with 
payment  for  results  (ecosystem  service).  Provide  guidance  for 
eco-schemes with payments based on results. 

BE, RO 

167  Premiums: allow for eco-scheme top-up payments. 

168 

Premiums: the mechanism for reducing payments provided for at 
the level of eco-schemes does not respect the principle of balanced 
and  appropriate  compensation  for  the  efforts  of  farmers.  It 
provides a disproportionate advantage for financial management 
at the expense of fair compensation and balancing environmental 
impacts. 

BE 

LU 

169 

Premiums:  allow  payments 
for  agri-environment-climate 
measures  (AECM)  /  eco-scheme  measures  that  exceed  the 
additional costs incurred and income foregone. 

DK, BE, LU 

The  Commission  welcomes  and  supports  Member  States  that  develop 
eco-schemes  with  payments  based  on  results,  several  of  which  already 
exist. In expert groups and the CAP Network, the Commission promotes 
exchanges of best practice for result-based schemes and discusses how to 
simplify interventions and minimize the administrative burden linked with 
the 
rural 
implementation  of  conditionality,  eco-schemes,  and 
development interventions. 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

Member  States  have  considerable  flexibility  in  setting  planned  unit 
amounts and their variability, according to the method of compensation, 
to ensure an appropriate reward for farmers' efforts. Lessons learned from 
current period will feed into the reflection on the post-2027 CAP. 

Eco-scheme payments  beyond the  costs/income foregone compensation 
principle are possible under Article 31 (7), point (a) of the CSP Regulation 
respecting  WTO  “green  box”  rules  (no  link  to  specific  production). 
Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

77 

 
 
Suggestions 

Proponents 

Assessment 

In addition to eco-schemes, annual commitments are possible for certain 
AECM  interventions  in  duly  justified  cases.  Lesson  learned  from  the 
current period will feed the reflection on the post-2027 CAP. 

Only  interventions  which  partially  or  fully  contribute  to  these  specific 
objectives are taken into account in the milestones and targets under these 
result indicators.  Lessons learned from the current period will feed into 
the reflection on the post 2027-CAP. 

The  revision  clause  is  only  relevant  for  multiannual  area-based 
commitments  since  rules  may  change  during  the  contract  with  the 
beneficiary and the terms may need to be adapted to new conditions or a 
new baseline. By contrast, investment support is a one-off operation that 
is  linked  neither  to  conditionality  (baseline)  nor  to  multiannual 
commitments (with yearly payments). 

170  Financing: allow annual AECM commitments. 

171 

Environment targets emanating from interventions that address 
environmental  and  climate-related  specific  objectives  should  be 
simplified for a more direct link between the intervention and the 
target. 

172 

CAP  -  Forestry  carry-over:  revision  of  the  principle  of  ‘new 
money,  new  rules  -  old  money,  old  rules’.  The  rules  of 
conditionality  and  cross  compliance  apply  to  multiannual  area-
based interventions for example AECM or forestry maintenance. 
The proposal is to apply the revision clause of Article 48 of EU 
Regulation  1305/2013.  The  Article  sets  out  rules  for  the 
measures/interventions for Articles 28, 29, 33 and 34, but does not 
have a rule for Article 21 on investments in developing forest areas 
and improving the viability of forests, paragraph 1. (a), (b), (c) 
(d). 

SE 

MT 

HU 

78 

 
 
 
III. FARM INCOME AND COMPETITIVENESS 

Suggestions 

Proponents 

Assessment 

173 

Threshold Small Farmer Scheme: increase the limit of payment 
for application of the small farmers scheme from EUR 1 250 to 
EUR 5 000 (Article 28 of the CSP Regulation). 

ES 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

CAP Strategic Plan - Small Farmers Scheme 

174 

175 

176 

CAP strategic plan - coupled income support interventions 

Potatoes:  inclusion  of  table  potatoes  in  the  list  of  products 
eligible  for  coupled  income  support  (Article  33  of  the  CSP 
Regulation). 

BG, HU 

Lessons  learned  from  the  implementation  of  the  CAP  2023-2027 
interventions, including that of coupled income support, will feed into the 
reflection on the post-2027 CAP. 

Water  Framework  Directive: 
the 
requirement for coupled income support to be consistent with the 
Water  Framework  Directive  (Article  109(2)(c)  of  the  CSP 
Regulation). 

remove  or 

reassess 

BG, CZ, EL, 
HR, HU, SK 

The  suggestion  was  not  taken  up  as  this  is  an  important  sustainability 
requirement for coupled income support. Lessons learned from the current 
period will feed into the reflection on the post-2027 CAP. 

Animals: abolish the condition of identification and registration 
of animals to access coupled income support (Article 34(2) of 
the CSP Regulation). 

DE 

This rule is necessary to ensure that payments are made for the correct 
number of eligible animals. Lessons learned from the current period will 
feed the reflection on the post-2027 CAP. 

79 

 
 
 
Suggestions 

Proponents 

Assessment 

177 

Animals: late registration of bovine and ovine animals should not 
disqualify the animals from coupled income support, provided the 
identification and registration of animals is performed by a date 
set by the Member State (Article 34(2) of the CSP Regulation).  

HU 

The registration of animals by a certain date in the claim year concerned 
is necessary to ensure that payments are made for the correct number of 
eligible  animals,  while  the  actual  date  is  left  for  the  Member  States  to 
decide. 

CAP strategic plan - Sectoral interventions 

Modification of the decision to transfer allocations from direct payments 
to other interventions in certain sectors is allowed in 2025 (Article 88(7) 
of the CSP Regulation). Such transfer would give producer organisations 
(POs) the possibility to implement operational programmes as from 2027, 
the last claim year of this programming period.  

The percentage level up to which allocations from direct payments can be 
transferred to interventions in ’other’ sectors (the only option for transfer 
to  these  sector  interventions  under  current  EU  legislation)  is  limited. 
However,  at  this  moment,  Member  States  do  not  even  implement  the 
transfer of the already planned amounts.  

The feasibility and impact of this proposal is being examined.   

The increase in the maximum number of requests for CSP amendments is 
included in the Commission proposal which is part of the simplification 
package. The Commission proposed to increase the number of requests 
for amendment of CAP Plans which a Member State may submit to two 
per  year  (up  from  one  per  year).  See  also  the  adopted  Simplification 
Regulation. 

A  modification  of  the  decision  to  transfer  allocations  from  direct 
payments to interventions in certain sectors is allowed in 2025 (Article 
88(7)  of  the  CSP  Regulation).  Such  a  transfer  would  give  POs  the 

178 

Financial allocation: increased transfer from direct payments to 
sectoral schemes. 

SK 

179 

Financial  allocation:  Member  States  should  be  allowed  to 
increase the allocations for sectoral interventions more than once 
during the entire CAP period 2023-2027. 

SK 

80 

 
 
Suggestions 

Proponents 

Assessment 

180 

Financial  allocation:  exclude  the  linking  of  Member  States' 
allocations to the financial year for certain types of interventions 
in the wine and apiculture sectors  

181 

Simplified  procedure:  the  administrative  burden  of  sectoral 
interventions  is  disproportionate.  If  support  received  by  a 
Member  State  is  less  than  2%,  the  Member  State  should  be 
allowed to follow a simplified procedure 

intensity: 

increasing 
Aid 
organisations from the current 50% to 60%. 

the  aid 

intensity  for  producer 

182 

183 

184 

LT 

FI 

IT 

possibility to implement operational programmes as from 2027, the last 
claim year of this programming period.  

This  is  linked to the  annual  nature of  the  EAGF  allocations,  which the 
planning per financial year for interventions in certain sectors in the CSP 
follows  throughout  the  current  programming  period.  Lessons  learned 
from the current period will feed into the reflection on the post-2027 CAP. 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

The current EU legislation already sets out a list of cases where POs in 
the fruit and vegetables sector can get 60% instead of 50%  EU support 
under specific conditions (Article 52(3) of the CSP Regulation). This list 
of  situations  where  an  increase  is  possible  had  already  been  extended 
compared  to  the  previous  list  in  Article  34(3)  of  Regulation  (EU)  No 
1308/2013.   

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

The  Commission  provided  on  25  July  2024  further  clarifications  to 
Member  States  on  the  possibility  to  pay  interim  payments  for  sectoral 
interventions. 

Partial  payments  for  sectoral  interventions.  Member  States 
should  be  able  to  provide  partial  payments  using  EU/national 
funding. 

ES, SK, HU 

EAFRD  interventions:  correlation  between  eligibility  and 
implementing  rules  for  sectoral  interventions  with  similar 
EAFRD interventions (amendment of the secondary legislation). 

RO 

This  issue  has  already  been  addressed  in  2022  with  the  new  secondary 
legislation  (Article  11(4)  to  (8)  of  Commission  Delegated  Regulation 
(EU) 2022/126) as regards water savings for instance. 

81 

 
 
Suggestions 

Proponents 

Assessment 

185 

186 

Guarantee:  cancel  the  condition  of  lodging  a  security  if  a 
producer  organisation  is  applying  for  an  advance  payment  in 
other sectors. 

Costs: the obligation to apply cost moderation to expenditure of 
any amount hinders the management of aid, such as in the case of 
apiculture. 

187 

Wine: simpler management of wine promotion measures in third 
countries,  simplification  of  administrative  costs,  simplified 
procedure for POs where support is a small share of turnover. 

188 

189 

190 

Wine: introduce new types of intervention that make it possible 
to  respond  to  the  needs  of  the  sector,  such  as  deferred 
restructuring. 

Proof  of internal  transport  of  POs:  due  to  complex  controls, 
reintroduce  an  exemption  limit  of  300  km  (Article  31  (6)  b  of 
Commission Delegated Regulation (EU) 2022/126)  

Wine:  simplify  the  definition  of  planted  areas  used  for  the 
vineyard  restructuring  measure,  provided  for  in  Article  42  of 
Commission Delegated Regulation (EU) 2022/126. 

The suggestion was not taken up. Authorising advance payments without 
lodging  a  security  would  present  a  risk  for  the  EU’s  financial  interests 
(EAGF). All the more considering that for interventions in certain sectors, 
there is no Member State co-financing involved. 

Member States can reduce the administrative burden in how the support 
is  distributed,  for  example  by  making  use  of  simplified  cost  options 
(SCOs) and applying flat rates. SCOs have been extended to all types of 
sectoral expenditure (Article 44 of the CSP Regulation). 

This suggestion was not taken up, as the intervention already offers a high 
level  of  flexibility  to  Member  States.  Further  simplification  must  be 
weighed against risks to the EU funds, which is considered high for these 
measures  (e.g.  requirement  of  reasonableness  of  costs,  which  was 
introduced via an amendment of Article 21 of Delegated Regulation (EU) 
2022/126).  Administrative  costs  are  also  covered  by  Article  23  of 
Commission  Delegated  Regulation  (EU)  2022/126,  already  providing 
flexibility  for  Member  States.  Lessons  learned  from  the  current  period 
will feed into the reflection on the post-2027 CAP. 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP taking into account also the provisions of Article 66(1) 
of the Common Market Organisation Regulation (Regulation 1308/2013) 
on replantings. Technical discussion with Member States are planned  in 

SK 

ES 

ES 

ES 

AT 

FR 

82 

 
 
Suggestions 

Proponents 

Assessment 

191 

Apiculture: updating the list of eligible expenditures in sectoral 
interventions for apiculture to include vehicles for transhumance. 

192 

193 

Olive  oil:  not  to  limit  the  financial  assistance  to  the  olive  oil 
sector to less than 15% (of the value of marketed production of 
each PO or association of POs) from 2025 onward. 

Fruit and vegetables: simplify the system of objectives for POs 
in the fruit and vegetables sector as regards applying recognition, 
and for operational programmes for specific interventions. 

expert  group  setting  (Expert  Group  for  Agricultural  Markets  /  Expert 
Group on the Implementation of the CAP Strategic Plans Regulation). . 

The  suggestion  was  not taken  up.  In  apiculture,  vehicles  are  only  used 
twice a year for the transhumance of beehives. Allowing vehicles to be 
eligible could lead to abuse. The possibility of support for the leasing of 
transport services for transhumance should address the needs of the sector 
in this regard.  

15% applies in 2025 and 2026. In 2027, 10% applies (Article 65(2) of the 
CSP Regulation).  Lessons learned from the current period will feed into 
the reflection on the post-2027 CAP. 

HR 

IT 

LV, PL 

The suggestion was not taken up to maintain a level playing field between 
POs. Lessons learned from the current period will feed into the reflection 
on the post-2027 CAP. 

194 

Fruit and vegetables: to revise the requirements imposed on 
POs in the fruit and vegetable sector, to make the aid measure 
more accessible to POs with small operational funds. 

LV 

195 

Fruit and vegetables: requirements for POs are too burdensome, 
especially on small farmers in the fruit and vegetables sector. 

MT 

The suggestion was not taken up. Small POs should abide by the same 
rules  as  bigger  POs,  for  example,  on  environmental  ring  fencing. 
Moreover, POs are free to concentrate their operational programmes in a 
few interventions that respond to their main priorities and are adjusted to 
their own resources. Article 52(3) of the CSP Regulation  already provides 
financial incentives for POs under certain conditions. 

Encouraging small farmers to form bigger economic structures to get a 
better position in the supply chain is the very purpose of this policy. It is 
the PO that has to assume the management of the operational programme, 
not the individual producer members. 

196 

Fruit  and  vegetables:  extend  the  list  of  cases  in  which  it  is 
assumed  that  a  PO  has  implemented  one  of  at  least  three 
obligatory  actions  (environment,  animal  welfare,  climate)  with 
eco-schemes. 

PL, PT 

The  suggestion  was  not  taken  up,  since  it  is  considered  important  to 
preserve the environmental contribution of POs. Lessons learned from the 
current period will feed into the reflection on the post-2027 CAP. 

83 

 
 
197 

198 

199 

200 

Suggestions 

Proponents 

Assessment 

Fruit  and  vegetables  -  irrigation:  procedure  for  accessing 
irrigation investments in fruit and vegetables interventions should 
be  simplified,  avoiding  reference  to  documentation  proving 
water. 

Fruit  and  vegetables:  do  not  change  the  objectives  of  POs' 
operational programmes, but make them much more flexible and 
simpler,  by  amending  Commission  Delegated  Regulation  (EU) 
2022/126.  This  includes  the  financing  of  irrigation,  and  the 
reduction of the carbon footprint and plastic packaging based on 
fossil  fuels.  Requirements  should  be  adapted  to  consider 
exceptional circumstances of drought. 

Fruit  and  vegetables:  clarification  of  Article  22(4)  of  the 
Commission  Delegated  Regulation  (EU)  2022/126.  To  more 
effectively  pursue  the  goals  of  reducing  CO₂  emissions  and 
plastics,  in  accordance  with  the  objectives  of  the  proposed 
Packaging  and  Packaging  Waste  Regulation,  it  is  necessary  to 
allow  Member  States  to  make  the  use  of  re-usable  ‘green’ 
packaging eligible for the purpose of combating and adapting to 
climate  change,  and  to  count  this  towards  the  15%  minimum 
spend on the environment. 

IT 

The suggestion was not taken up. Provisions for irrigation investments are 
aligned with rules for similar rural development interventions. 

COPA-
COGECA 

Objectives  of  the  sectoral  interventions  are  laid  down  in  the  CSP 
Regulation.  Lessons  learned  from  the  current  period  will  feed  into  the 
reflection on the post-2027 CAP.  

COPA-
COGECA 

The suggestion was not taken up. Re-usable ‘green’ packaging counts as 
production  costs  and  should  not  be  eligible.  However,  investments  in 
innovative  assets,  methods  and  actions  relating  to  re-usable  ‘green’ 
packaging are eligible. 

Fruit  and  vegetables: 
the  sorting  and  packaging  costs 
reimbursed  to  fruit  and  vegetable  POs  as  compensation  for  the 
costs incurred in withdrawing products from the market for free 
distribution have been changed from ‘lump sums’ to ‘maximum 
values’  (Article  33  of  Commission  Delegated  Regulation  (EU) 
2022/126). Therefore, these costs must be demonstrated in detail 
represents  a  considerable 
during 
is 
administrative  and  bureaucratic  burden  for  POs 

the  assessment.  This 

that 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

PT 

COPA-
COGECA 

84 

 
 
 
Suggestions 

Proponents 

Assessment 

disproportionate  to  the  modest  scale  of  withdrawal  operations, 
with  the  risk  of  favouring  alternative  destinations  (e.g.  animal 
feed) to the detriment of free distribution to people in need. 

201 

Support  for  POs  under  the  cooperation  measures  must  make  it 
possible to support not only installation, but also maintenance. 

PL 

The suggestion was not taken up. The current EU legal framework allows 
support  for  setting-up  producer  groups,  producer  organisations  and 
interbranch  organisations,  limited  to  the  first  5  years  following 
recognition.  After  this  period  the  expectation  would  be  that  the 
cooperation between POs, if profitable for participants, would remain in 
operation  with  the  costs  of  continued  cooperation  funded  by  the 
participants  themselves.  Maintaining  the  cooperation  after  the  5-year 
period  would  be  considered  as  an  operational  cost  for  participating 
producers and not eligible for support. 

202 

Simplify  PO  support:  simplify  the  support  for  producer 
organisations  by  making  them  eligible  for  support  in  other 
interventions,  combined  with  ringfencing  of  the  EU-funding, 
instead  of  having 
interventions  with 
requirements  that  are  different  to  similar  interventions  in  the 
strategic plan. 

separate 

sectoral 

SE 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

203 

Financing POs: allow financing before 2026 of commitments in 
the M09 measure (setting up producer groups and POs) of the 
RDP 2014-2020 in the framework of the CAP Plan 2023-2027 
(Article 155 (4) and (5) of the CSP Regulation). 

PL  

The suggestion was not taken up. Support for setting-up POs may be paid 
pursuant to Regulation (EU) No 1305/2013 until 31 December 2025. The 
support  shall  be  paid  in  annual  instalments  for  no  more  than  5  years 
following the date on which the PO was recognised. Remaining payments 
of such instalments after 31 December 2025 may be financed under the 
CAP  Plans  pursuant  to  the  conditions  in  Article  155(4)  of  the  CSP 
Regulation. However, it is not possible to pay for carry-over commitments 
before 31 December 2025 under the CAP  Plans. 

85 

 
 
Suggestions 

Proponents 

Assessment 

204 

Costs: introduction of a general approach for the calculation of 
eligible  costs  in  connection  with  the  examination  of  the 
appropriateness of costs: definition of a general percentage for the 
reduction  of  costs,  e.g.  on  the  basis  of  past  projects,  graduated 
according to the type and size of the projects. 

The current rules seem to be flexible enough and therefore no change is 
envisaged. 

AT 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP.  

205 

Support  rate:  increase  support  rate  for  collective  investments 
and organic farming. 

LT 

The suggestion was not taken up. Lessons learned from the current 
period will feed into the reflection on the post-2027 CAP.  

CAP Strategic Plan Regulation - Investment interventions 

Irrigation:  simplify  conditions  for 
(alignment with State aid rules, simpler eligibility conditions). 

irrigation 

investments 

206 

207 

Irrigation:  the  Commission  should  develop  guidelines  for  the 
interpretation of eligibility criteria for investments in irrigation. 

208 

209 

Irrigation: exempt irrigated areas from the obligation to rotate 
(GAEC  7)  and  from  having  to  allocate  4%  to  non-productive 
areas (GAEC 8).  

Costs:  lift  the  obligation  to  have  three  offers  for  checking  the 
reasonableness of the cost of investments. 

The suggestion was not taken up since it would hamper the achievement 
of  the  policy  objectives  of  the  CAP  2023-2027.  Detailed  rules  for 
investments in irrigation are needed to ensure that agricultural water use 
does  not  put  the  good  status  of  water  bodies  at  risk.  The  requirements 
ensure  that  investments  are  aligned  with  the  objectives  of  the  Water 
Framework Directive. The requirements for State aid are also aligned with 
those of the CSP Regulation. 

The  suggestion  was  not  taken  up.  EU  rules  on  interventions  on 
investments in irrigation (e.g. Article 74 of the CSP Regulation) already 
provide sufficiently detailed requirements that enable Member States to 
design such interventions.  

Partially  addressed 
Simplification Regulation. 

through 

the  Simplification  package.  See 

the 

The CSP and the Horizontal Regulations no longer provide for rules on 
the  reasonableness  of  costs,  unlike  the  legislation  for  the  previous 

CY, FR, HU, 

MT, LT 

ECVC 

HU 

ES 

BE 

86 

 
 
 
 
Suggestions 

Proponents 

Assessment 

210 

211 

Forestry  carryover:  according  to  Article  155  of  the  CSP 
Regulation,  on  the  eligibility  of  certain  types  of  expenditure 
relating to the CAP Plan period, the carry-over of expenditure is 
only  available  for  area-based  interventions.  This  should  be 
expanded to forestry interventions.  

Young  farmers:  young  farmers  should  be  able  to  receive 
investment support if the investment serves to comply with the 
applicable EU standards, on the condition that the investment is 
implemented within 24 months of the establishment of the young 
farmer's  farm,  or  during  the  period  of  implementation  of  the 
measures  specified  in  their  business  plan.  This  would  be 
especially  important  for  young  animal  farmers  (wastewater 
treatment).  

212  Type  of  beneficiary:  allow  collectives  to  be  beneficiaries  of 
subsidies,  for  example  a  cooperative.  At  the  moment,  only 
individuals may request subsidies 

planning  period.  However,  Member  States  have  an  obligation  to  take 
measures to ensure sound financial management and effective protection 
of the EU's financial interests based on Regulation (EU) 2018/1046 and 
Articles 59(2) and 60(1) of the Horizontal Regulation. It is therefore for 
Member States to determine appropriate measures to comply with these 
obligations,  such  as  the  verification  of  the  reasonableness  of  costs  for 
subsidised operations. 

The suggestion was not taken up. According to Article 155(4) of the CSP 
Regulation,  Member  States  already  have  the  possibility  to  carry  over 
certain non-IACS interventions under the conditions in that Article. This 
also  includes  non-IACS  forestry  interventions  (Articles  23  to  26  of 
Regulation (EU) 1305/2013). 

HU 

FR, HU 

Under CAP Plans considerable investment support is available for young 
farmers. To strengthen generational renewal in farming, lessons learned 
from the current period will feed into the reflection on the post-2027 CAP. 

NL 

Article 73 of the CSP Regulation does not exclude cooperatives or other 
similar types of organisations from investment support.  

213 

Increasing the ceiling for working capital to align with de minimis 
rules. 

LT  

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

Financial instruments 

87 

 
 
214 

215 

216 

217 

218 

219 

220 

221 

Suggestions 

Proponents 

Assessment 

Reduce the administrative and control requirements for the use of 
financial instruments (purchase of land). 

Reduce the information burden for final recipients under financial 
instruments.  

EE 

PL  

The  suggestion  was  not  taken  up.  Rules  regulating  the  creation  and 
implementation of financial instruments have already been considerably 
simplified.  

The  suggestion  was  not  taken  up.  This  would  result  in  a  considerable 
reduction of the visibility of EU programmes that benefit the public. 

Risk and crisis management 

Derogations: allow the use of Article 148 of the CSP Regulation 
(adoption of implementing acts) to introduce derogations beyond 
a period of 12 months. 

HU, HR, PT 

The  suggestion  was  not  taken  up.  The  aim  of  Article  148  of  the  CSP 
Regulation is to provide quick but temporary responses to problems which 
arise during the implementation of the Regulation. If the problem persists 
there is time for an amendment of that Regulation to establish a longer-
term solution, using an ordinary legislative procedure.  

Create a national crisis payment envelope: increase CAP Plan 
allocations  for  crisis  payments  (e.g.  2%  of  a  Member  State’s 
CAP  Plan  envelope  for  crisis  measures),  as  an  exceptional 
temporary relief measure.  

Crisis  reserve:  setting  up  of  a  reinforced  crisis  reserve  to  be 
financed from non-CAP resources. 

Activate dynamic crisis management measures (storage and 
other measures).   

Risk  management:  more  flexible  rules  for  using  DP  for  risk 
management (Article 19 of the CAP Regulation). 

Risk management: allow alternative calculation of losses under 
a  risk  management  scheme  (flexibility  in  calculating  income 
loss, with the calculation based on turnover instead of yield loss 
or based on 4- or 8- year Olympic averages). 

EL, HR, HU, 
CY, BG 

The suggestion was not taken up. Lessons learned from the current period 
will feed into the reflection on the post-2027 CAP. 

The suggestion was not taken up. Lessons learned from the current period 
will feed into the reflection on the post-2027 CAP. 

Market  safety-net  measures  are  activated  when  required  by  the  market 
situation.  The  Commission  continuously  monitors  the  situation  on  EU 
agricultural markets.  

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

The  current  EU  legal  framework  already  grants  a  lot  of  flexibility  for 
Member States to calculate losses. For instance, a calculation based on 
loss of farm income instead of loss in production yield is already possible. 
For other rules such as the 3-year or Olympic average, the lessons learnt 

IT 

BE 

HU 

FR, PL 

88 

 
 
Suggestions 

Proponents 

Assessment 

222 

Risk  management  guidance:  Commission  guidance  for  the 
implementation  of  risk  management  tools  in  the  form  of  a 
measure  sheet,  as  was  done  for  the  previous  programming 
period. 

223 

Risk management: allow verification of the reasonableness of 
costs for insurance premia at the level of the insurance company 
offering the products. 

FR 

FR 

224 

Risk  management:  allow  risk  management  tools  to  calculate 
production loss per crop/animal. 

RO 

225 

Top-up  crisis  payments:  future  crisis  payments  as  top-ups  to 
existing support schemes 

FI 

from  CAP  implementation  in  the  current  period  will  feed  into  the 
reflection on the post-2027 CAP. 

Guidance  has  already  been  provided  to  Member  States  on  risk 
management. The Commission will engage with Member States to discuss 
the lessons learnt from the first years of implementation. 

The CSP and the Horizontal Regulations no longer provide for rules on 
the  reasonableness  of  costs,  unlike  the  legislation  for  the  previous 
planning  period.  However,  Member  States  have  an  obligation  to  take 
measures to ensure sound financial management and effective protection 
of the EU's financial interests based on Regulation (EU) 2018/1046 and 
Article 59(2) and 60(1) of the Horizontal Regulation. It is therefore for 
Member States to put in place appropriate measures to comply with these 
obligations,  such  as  the  verification  of  the  reasonableness  of  costs  for 
subsidised operations. 

Subject  to  a  SWOT  analysis  and  needs  assessment  of  the  CAP  Plan, 
Member States could introduce a sectoral intervention in sectors referred 
to in Article 42, point (f) of the CSP Regulation, comprising a production 
loss  risk  management  tool  for  a  certain  sector,  such  as  production 
insurance.  In  this  case  the  calculation  of  losses  should  be  either  at  a 
holding level or at the level of the holding’s activity in the sector.  

Lessons learnt from the current period will feed into the reflection on the 
post-2027 CAP. 

Exceptional  measures  based  on  Regulation  (EU)  No  1308/2013  and 
providing emergency support funded through the agricultural reserve aim 
to address market disturbances or crises. Using the EU agricultural reserve 

89 

 
 
Suggestions 

Proponents 

Assessment 

226 

Declarations: simplify declarations for disasters and crop 
damage. 

ECVC 

to top-up interventions in the CAP Plans would deviate from the objective 
of the reserve.  

Lessons  learned  on  the  use  of  the  agricultural  reserve  and  crisis 
management measures will feed into the reflection on the post-2027 CAP. 

This  matter  falls  under 
the  Member  States’  responsibility.  For 
compensation under the interventions’ risk management tools (Article 76 
of the CSP Regulation), a formal recognition of the risk event in relation 
to production losses is no longer required (as was the case in the previous 
CAP programming period). 

227 

228 

229 

Common market organisation 

Wine: extend the validity of all vineyard planting authorisations 
to 8 years instead of 3 years. Elimination of the validity limit of 
replanting rights.  

ES, IT 

This suggestion was not taken up. Extending the validity of authorisations 
for  new  plantings  would  add  more  uncertainty  to  the  evolution  of 
production potential. A wider discussion on wine-related issues will take 
place in the high-level group on wine that the Commission is setting up, 
which will provide an input for future reflections on the EU wine policy 
under the post-2027 CAP. 

Wine: allow modifications of authorisations for the location of 
vineyard plantings to be requested and approved without prior 
justification, as long as the other requirements are met. 

ES 

The feasibility and impact of this suggestion is being examined. 

Producer organisations (POs): suggestion for manuals on the 
recognition 
interprofessional 
organisations, practices, and exemptions from competition rules 
applicable to the agri-food sector. 

of  POs, 

operation 

and 

The EU CAP network regularly publishes good practices in implementing 
the CAP. It organises every year a forum to exchange best practices in the 
food  supply  chain.  Recognition  of  POs  and  IBOs  (interbranch 
organisations) often relies on national specificities and procedural rules 
that an EU-level manual would not be able to capture. Guidance on the 
exception to competition rules under Article 210a of Regulation (EU) No 

PT 

90 

 
 
Suggestions 

Proponents 

Assessment 

1308/2013 has been provided as a part of new ‘Commission guidelines on 
the exclusion from  Article 101  of  the  Treaty  on  the  Functioning  of the 
European  Union  for  sustainability  agreements  of  agricultural  producers 
pursuant to Article 210a of Regulation (EU) No 1308/2013’ (C/2023/1446 
of 8 December 2023). 

The  manual  ‘Establishing  an  Operational  Programme  -  supporting 
producer organisations’ is also available: 

https://op.europa.eu/en/publication-detail/-/publication/beca5d94-7d21-
11ee-99ba-01aa75ed71a1/language-en.  

91 

 
 
IV. OTHER ELEMENTS OF THE CAP/OTHER INSTRUMENTS OF AND RELATED TO THE CAP 

Suggestions 

Proponents 

Assessment 

Knowledge, digitalisation, advice 

230 

FAST: make the use of the electronic Farm Sustainability Tool 
(FAST) optional for Member States and for farmers (Article 15 
of the CSP Regulation). 

BG, HU, RO 

231 

Knowledge: provide continuous education and information and 
increase targeted support to farmers about the applicable rules. 
Strengthen knowledge and advice throughout the agri-food value 
chain to reduce asymmetry of information. 

CZ, PT 

232 

Digital  tools:  develop  digital  tools  and  platforms  for  easier 
reporting, applications for support and administrative actions. 

233 

Single  contact  point:  create  a  single  contact  point  for  all 
communication,  to  reduce  the  need  to  approach  different 
institutions. 

CZ 

CZ 

92 

It  is  optional  for  farmers  to  use  FAST  but  mandatory  for  Member 
States to offer it to farmers. Making this optional for Member States 
would go against the environmental ambitions of the 2023-2027 CAP 
and  the  need  to  support  farmers  in  the  necessary  sustainability 
transition. 

The Farm Advisory Services are funded under the CAP Plans for this 
purpose.  

The Commission recognises the importance of knowledge, exchange 
of good practices and advisory services. At EU level this is done, for 
example, by the EU CAP network (e.g. annual forum on best practices 
in  the  food  supply  chain).  Following  its  commitments  in  the 
simplification  package,  the  Commission  has  organised  exchanges 
with Member States and stakeholders on how to make better use of 
these knowledge/advisory tools. 

It is already possible to address this issue within the current EU CAP 
framework. 

It is already possible to address this issue within the current EU CAP 
framework. 

At EU level, the Commission has a single contact point through which 
citizens may make any communication. 

 
 
 
Suggestions 

Proponents 

Assessment 

234 

235 

Digital  farm  notebook:  the  obligation  to  have  a  digital  farm 
notebook should be removed given connectivity problems, lack 
of skills, age structures, and access to advisory services. 

COPA-
COGECA 

Digital  tools:  do  not  rely  on  the  hyper  technologisation  of 
administrative tasks.  In addition, the use of data, if it is not truly 
protected, is a threat. 

ECVC 

There is no EU-level obligation in the EU CAP framework to have a 
‘farm  digital  notebook’.  Nevertheless,  digital  administrative  tools, 
including for CAP support, will become increasingly important and 
therefore  it  is  important  to  accompany  and  support  farmers  in 
managing and using such digital tools effectively and efficiently. The 
implementation and administration of digital tools is a Member State 
responsibility. 

CAP strategic plans - social conditionality 

236 

Remove social conditionality.  

BG, HU, LV, 
PL, SK, RO, 
CY 

237 

Postpone the application of social conditionality. 

HR, SI, BE 

238 

Align social conditionality with other conditionality. 

FI 

239 

Avoid double penalties between systems of conditionality and 
cross  compliance.  With  social  conditionality,  farmers  may  be 
subject to double penalties. If a farmer makes a small mistake, 
this could lead to a sanction on CAP payments and a sanction 
through national legislation on working conditions.  

COPA-
COGECA 

The suggestion was not taken up. The CSP Regulation already grants 
Member States the possibility to delay to 2025 the implementation of 
social conditionality, or to start applying it earlier. Several Member 
States already implement the social conditionality system. Postponing 
its application beyond 2025 would affect the level playing field in the 
EU and would hamper the achievement of the policy objectives of the 
2023-2027 CAP in the area of social sustainability.  

In  any  event,  social  conditionality  should  not  add  an  additional 
complication for farmers since it relies on the existing implementation 
and control systems in Member States. 

The  suggestion  was  not  taken  up.  By  expanding  the  system  of 
conditionality for direct payments under the CAP, the co-legislators 
have  chosen  to  include  the  obligation  for  Member  States  to  apply 
administrative penalties linked to a range of social rights laid down in 
EU legislation, such as written contracts and rules on safety and health 
at work.  

93 

 
 
 
Suggestions 

Proponents 

Assessment 

Organic farming 

240 

Automated IT system to record feeding regimes and growing 
periods per group of animals. 

241 

Guidelines for organic livestock products should have all the 
requirements in a single place. 

LT 

LT 

242 

Plant reproductive materials: derogation until 2036 from the 
requirement to use only plant reproductive material. 

LT 

243 

Fewer  secondary  acts:  reduction  of  the  number  of  delegated 
and implementing acts for organic farming. 

PL 

EU legislation does not prevent the introduction of such IT systems. 
However, it  should  be  considered  whether  this  would  contribute to 
simplification. 

The  Commission  has  published  notices  on  the  use  of  veterinary 
medicines  and  on  apiculture.  In  addition,  DG  AGRI  discusses  the 
correct implementation of the EU provisions in great technical detail 
with the Member States.   

According  to  Article  53(7)  of  Regulation  (EU)  2018/848  the 
Commission will present a report on the availability of organic plant 
reproductive material by 31 December 2025. Based on this report and 
the  assessment  of  the  situation  in  the  sector,  the  Commission  will 
consider modifying the legislative act. It may do this by extending the 
derogation referred to in point 1.8.5 of Part I of Annex II or by ending 
the  derogation  on    a  date  earlier  than  31  December  2036.  The 
empowerment could be used from 1 January 2029 and must follow 
the applicable procedure. In addition, certain organic operators have 
invested  in  developing  organic  plant  reproductive  material  and  the 
extension  of 
the 
development of their activities. 

the  current  derogation  would  undermine 

The secondary legislation associated with Regulation (EU) 2018/848 
stems directly from provisions in the Regulation. The co-legislators 
decided to leave the settlement of certain technical issues out of this 
Regulation  and  instead  to  empower  the  Commission  to  develop 
specific secondary legislation on these issues.  

94 

 
 
Suggestions 

Proponents 

Assessment 

244 

Agricultural land: propose a directive on agricultural land and 
establish a European agricultural land observatory. 

ECVC 

Other issues 

The  suggestion  was  not  taken  up.  Land  markets  are  within  the 
competence  of  the  Member  States.  The  Commission  monitors  a 
number of key variables in relation to agricultural land, considering 
the  importance  of  access  to  land,  which  also  affects  generational 
renewal.  

Other general suggestions for the CAP 

CAP Plans: simplify the intervention logic of CAP Plans, focus 
on ‘strategic elements’, take a multi-year, more result-oriented 
approach,  reduce  the  level  of  detail  required  in  measures  and 
actions. Strive for administrative simplicity. 

AT, CZ, EE, 
EL, FI, HU, 
LV, MT, SE, 
SI, SK, BE 

Member States have considerable flexibility in how they design their 
CAP Plans to address most of these suggestions. 

Lessons learned from the current period will feed into the reflection 
on the post-2027 CAP. 

245 

246 

247 

Take a flexible approach in CAP legislation to take account of 
different conditions and needs of various agricultural businesses 
and regions. Strengthen decision-making powers at the level of 
individual Member States. 

Stability:  set  a  longer  CAP  programming  period.  Avoid 
significant  changes  to  CAP  in  the  medium  term.  Set  realistic 
timeframes  for  the  implementation  of  new  or  modified 
legislation under CAP and a period of tolerance to allow people 
to understand the new CAP rules.  

248 

Balance the environmental and climate elements of CAP to take 
account of the economic impacts on the sector. 

SK 

95 

SI 

It is already possible to address this issue within the current EU CAP 
framework. 

SI, BE, IE 

The CAP programming cycle follows the 7-year period of the MFF 
and  provides  considerable stability.  The  Commission  agrees  on  the 
importance  of  the  stability  of  CAP  support,  and  this  is  why  its 
simplification package  proposed limited changes, keeping the main 
elements  of  the  2023-2027  CAP  intact.  Lessons  learned  from  the 
current period will feed into the reflection on the post-2027 CAP. 

This is the case of the current CAP policy with balanced objectives 
for  the  economic,  social,  and  environmental  aspects  of  agricultural 
sustainability. 

 
 
Suggestions 

Proponents 

Assessment 

249 

250 

251 

252 

CAP budget: the CAP should be adequately financed, with the 
objective of supporting farmers' income, ensuring food security, 
and  maintaining  a  viable  rural  area.  The  current  financial 
allocation  is  not  sufficient  to  ensure  the  necessary  balance 
between economic and environmental sustainability. 

CAP  budget:  the  budget  intended  for  the  CAP  should  be 
devoted  exclusively  to  agriculture.  Environmental  and  rural 
needs should be addressed outside the CAP budget. 

CAP process: follow-up the Strategic Dialogue on the Future of 
Agriculture. Importance of early engagement of farmers and the 
AGRIFISH Council.  

IT 

BE 

IE 

Income: adaptation of the EU legislative framework to regulate 
and guarantee a fair income for farmers, including the revision 
of the Unfair Trading Practices (UTP) Directive, the creation of 
a  mechanism  for  fair  price  transmission  throughout  the  value 
chain and promote collective actions and collaboration between 
sector partners across the supply chain. 

COM AGRI, 

BE 

Lessons learned from the current period will feed into the reflection 
on the post-2027 CAP. 

Lessons learned from the current period will feed into the reflection 
on the post-2027 CAP. 

The Commission agrees that it is important to engage with farmers 
and  other  stakeholders  at  an  early  stage  and  will  pursue  this  in 
preparing  the  future  policy  initiatives.  The  Strategic  Dialogue 
delivered its report on 4 September 2024 and it is being discussed with 
other EU institutions and with stakeholders. 

This issue is covered by the reflection paper on the position of farmers 
in the food supply chain sent by the Commission to the co-legislators 
in  March  2024.  This  paper  lists  short-term  measures  that  aim  to 
improve  the  position  of  farmers,  in  particular  as  regards  their 
remuneration.  In  the  longer  term,  the  paper  mentions  the  on-going 
evaluation of the UTP Directive, and a specific study on experiences 
in different Member States on such an approach. These will feed into 
the  reflection  on  possible  amendments  to  Regulation  (EU)  No 
1308/2013  and  the  UTP  Directive,  while  respecting  the  basic 
principles of market orientation of EU agriculture and of the freedom 
of the parties to set the parameters of their contractual relations.   

96 

 
 
 
 
Suggestions 

Proponents 

Assessment 

Statistics and the Farm Sustainability Data Network (FSDN) 

Implementing  Regulation 

The  discussion  with  Member  States  on  the  new  variables  for  the 
(EU) 
FSDN  has  been  concluded. 
2024/2746, which sets out the FSDN variables, was published on 30 
October  2024.  The  variables  were  carefully  defined  through  close 
collaboration  with  Member  State  experts,  with  the  aim  of  ensuring 
they  are  relevant  for  sustainability  analysis  at  farm  level  while 
minimising the administrative  burden of  data collection  on  farmers 
and  national  administrations.  To  achieve  this,  the  principle  of  'ask 
once  and  reuse  multiple  times'  was  applied  wherever  possible.  For 
example,  variable definitions  we  aligned  with  those  used in certain 
statistical surveys, such as the Integrated Farm Statistics (IFS) or the 
Survey on Agricultural Input and Output (SAIO), taking advantage of 
the fact that FSDN data is collected at farm level, providing a more 
detailed perspective. 

A study on interoperability between the IFS and FSDN is currently 
ongoing,  involving  both  national  statistical  institutes  and  the  farm 
accountancy  data  network  (FADN)/FSDN  liaison  agencies.  The 
Commission continues to engage with Member States on improving 
data-sharing at both EU and Member States level. 

The statistics on plant protection products (PPP) use collected under 
the SAIO and FSDN are fundamentally different in nature. While the 
SAIO aims to provide solid PPP use statistics at country level, helpful 
for analysing trends in usage, including as regards the targets set by 
the Farm to Fork Strategy, the FSDN data on PPP use will be collected 

253 

FSDN: reduction of the number or frequency of variables to be 
collected from participating farms. 

DE, DK, FI 

COPA-
COGECA 

254 

Reuse the data collected: enable the retrieval and reuse of data 
already  collected  under  other  EU  legislation  or  systems 
(integrated farm statistics, IFS). 

255 

Statistics on plant protection products: request to carry out an 
the  notification 
the  cumulative  effect  of 
assessment  of 
requirements  for  multiple  statistical  data  (SAIO,  FSDN, 
integrated  farm  statistics,  etc.),  (Regulation  (EU)  2022/2379, 

DK 

LU 

97 

 
 
Suggestions 

Proponents 

Assessment 

Implementing Regulation 2023/564 on the content and format of 
the records of plant protection products). 

The School scheme 

256 

Remove 
participation. 

the  obligation 

to  approve  applicants  prior 

to 

LV 

98 

for  a  sample  of  farms  to  allow  in-depth  analysis  of  the  farm-level 
interrelation between PPP use and other farm management decisions, 
and the impact of policy interventions on these decisions, as well as 
the associated economic, social and environmental outcomes.  

In  the  absence  of  the  obligation  to  set  up  electronic  registers  at 
Member State level, the SAIO provides for a lower coverage for PPP 
use statistics to be collected as of 2028 (85% of usage instead of 95%).  

This burden reduction for the collectors should be carefully weighed 
against the necessity to collect the data from individual records, which 
however  would  considerably  be  alleviated  by  the  compulsory 
from  2026. 
electronic 
Additionally,  digitalisation  can  help  meet  the  record-keeping 
requirements established for professional users since 2009. 

record-keeping  of  pesticides  use  as 

Substantial financial support will be granted to Member States under 
the SAIO to help set up the collection of statistics on PPP use for the 
first  reference  year  (2026).  Similarly,  under  the  FSDN,  Member 
States will be able to benefit from support to set up and run the data 
collection system, as well as a transition period for collecting these 
data. 

The Commission considered an amendment of Delegated Regulation 
(EU) 2017/40 to remove the obligation for Member States to approve 
aid applicants (business operators participating in the School scheme) 
prior  to  their  participation  in  the  scheme  and  discussed  it  with 
Member States on 23 May and on 20 June 2024 (Expert Group for 
Agricultural Markets). Based on Member States’ feedback it was. 

 
 
 
Suggestions 

Proponents 

Assessment 

concluded  this  change  would  not  simplify  the  application  approval 
process 

Promotion programme 

257 

Simplification  of  management  procedures  (checks,  interim 
payments, sanctions). 

ES, LV 

to  Commission 

Implementing  Regulation 

The suggestion was addressed. The Commission is preparing targeted 
amendments 
(EU) 
2015/1831.  Among  other  changes,  reporting  obligations  could  be 
reduced  from  three  to  two  times  per  (3-year)  programme  for  both 
business-to-authority  and  authority-to-authority 
In 
addition, the content of reporting obligations related to payments will 
be reviewed to avoid overlap between reporting obligations under the 
final report and under the final interim report. 

reporting. 

Marketing standards and origin labelling 

258 

259 

Simplify marketing standards: simplify the existing rules and 
adjust  them  to  the  General  Food  Law  Regulation.  Avoid 
expanding  them  to  other  products  (Article  75  of  the  common 
market organisation regulation).  

Proportionality  of  marketing  standards:  the  proportionality 
and necessity of certain marketing standards should be assessed 
so as not to penalise small family businesses, or  structures in 
rural regions e.g. as regards the marketing standards applicable 
to eggs. 

DK 

LU 

99 

Marketing standards are tailor-made and proportionate to the market 
characteristics  and  challenges  for  certain  products.  They  have,  in 
addition, been subject to a recent evaluation, followed by a general 
exercise of simplification and technical adaptation, accompanied by a 
thorough impact assessment. This is why only a reduced number of 
agricultural  products  are  subject  to  marketing  standards.    The 
adoption  of  new  marketing  standards  will  follow  a  needs-based 
approach.  

 
 
 
 
 
 
 
V. LEGISLATION OUTSIDE THE CAP 

Suggestions 

Proponents 

Assessment 

EU legislation and legislative process 

Impact  assessments:  call  for  impact  assessments  of  new 
European Green Deal legislation, especially on the environment, 
to take better account of the viability of the primary sector. 

Call to review the cross-cutting requirements on environment and 
climate  to  determine  the  need  for  any  exceptions,  transition 
periods or alternative proposals, including maintaining the status 
quo, to facilitate compliance. 

CY, CZ, EL, 
RO, 

COM AGRI 

The  Commission  agrees  on  the  importance  of  thorough  impact 
assessments  and  will  continue  its  practice  in  line  with  Better 
Regulation principles where, among other issues, the competitiveness 
and consistency of legislation are mandatory topics to be examined.    

Analysis  of  burden:  assess  the  burden  of  multiple  laws  on 
farmers. Develop methods/tools for analysis of the simultaneous 
burdens from multiple pieces of legislation on the different types 
of farmer, including the CAP as a tool to identify potential areas 
of legislation where it is necessary or possible to simplify.  

SE 

The Commission agrees on the importance of cumulative assessment 
of impacts and consistency of legislation. 

The  ongoing  study  on  the  administrative  burden  and  simplification 
will  provide  insights  into  the  sources  of  the  burdens  that  weigh  on 
farmers. The results of the study are expected by early 2025. 

260 

261 

262 

Rural  proofing:  call  for  the  rural  proofing  of  EU  proposed 
legislation.  Ensure  the  consistency  and  complementarity  of  the 
relevant policies. 

SE, FI, 

COPA-
COGECA 

The use of rural proofing is already part of the Commission’s Better 
Regulation  methodology  and  is  essentially  implemented  through 
territorial  impact  assessments.  Better  Regulation  also  envisages  the 
assessment  of  the  impact  of  EU  rules  on  SMEs,  including  rural 
businesses. 

100 

 
 
 
 
 
 
Suggestions 

Proponents 

Assessment 

Consistency  between  laws  affecting  farmers.:  call  to  ensure 
consistency and complementarity between the different policies, 
legislative proposals and acts that affect farmers (e.g. between the 
CAP  and  legislation  on  deforestation  and  nature  restoration, 
waste, the circular economy and trade) and for a clear framework 
with a long-term perspective to enable operators to plan ahead. 

FI, LV, LU, 
MT 

COPA-
COGECA 

CEJA 

legislation:  call  for 

timely 
Timely  preparation  of 
preparation and adoption of EU legislation to give Member States 
enough  time  to  set  up  systems  and  procedures,  and  to  provide 
certainty to operators. Call for swifter provision of answers and 
interpretation from the Commission. 

the 

CY, CZ, FI, 
HU, SI 

Deadlines: 
environmental and climate legislation. 

realistic 

set 

deadlines 

for 

implementing 

CZ, SI, RO 

263 

264 

265 

266 

Taxing  pollution:  additional  taxation  in  terms  of  pollution 
should not be levied on farmers. 

MT 

101 

The Commission agrees that policies and legislation  aimed at farms 
must  be  consistent.  The  Commission  encourages  Member  States  to 
reflect on the interplay of different measures when they implement EU 
legislation. 

The Commission takes note of this request. The Commission agrees 
that the stability and predictability of the legal framework is important 
for  Member  States  and  farmers.  This  issue  will  be  taken  into 
consideration in the work on the post-2027 CAP, which should build 
on  existing  frameworks  and  structures  that  are  well  established  and 
have proven to function adequately (CAP Plans, control systems, etc). 
As a means of cooperation, the Commission shall continue to engage 
Member States in the reflection on upcoming legislation and to hold 
ad hoc consultations. The timing of the adoption and entry into force 
of new legislation also depends on the EU co-legislators. 

The Commission takes note of this request. Climate and environmental 
legislation work with a long-term perspective and should continue to 
do so. 

The  CAP  supports  farms  in  the  transition  to  a  sustainable  farming 
model.   

Any  proposals  for  changes  to  EU  environmental  legislation  are 
accompanied  by  impact  assessments  to  assess  the  policy  options 
available,  including  different  tools  and  instruments  to  address 
pollution.  In  particular,  these  impact  assessments  also  analyse  the 
impacts on all stakeholders concerned. 

 
 
 
 
Suggestions 

Proponents 

Assessment 

Research 

267 

Horizon: 
the  reporting  requirements  for  Horizon  multi-
stakeholder  projects  make  it  very  difficult  for  farmers  to 
participate. 

COPA-
COGECA 

Trade 

268 

Standards in trade agreements: trade agreements between the 
EU and non-EU countries should require the same EU standards 
on health, food, environment, and labour rights, avoiding 'import 
tolerance'  for  all  imported  food  products.  Consider:  mirror 
clauses, quantity quotas and monitoring of compliance. 

IT, MT, BE, 

 COM AGRI 

102 

The reporting related to Horizon-funded projects applies to all projects, 
including those with a multi-actor approach. On behalf of the project 
consortium,  the  project  coordinator  submits  all  reports,  payment 
requests, proof of deliverables and other documents as per the grant 
management between the Commission and the project consortium. The 
reporting  obligations  for  the  different  actors  involved  in  the  project 
(including  farmers)  are  largely  organised  and  decided  by  the 
consortium.  At  the  same  time,  a  project  officer  at  the  Research 
Executive Agency accompanies the consortium throughout the project 
implementation  and  provides  assistance  to  project  coordinators  to 
streamline reporting on project implementation.   

All  agri-food  imports  must  already  comply  with  EU  sanitary  and 
phytosanitary requirements. Going one step further and envisaging the 
application of certain EU process and production methods standards to 
imports  (on  a  case-by-case  basis  and  in  line  with  WTO  rules)  is  a 
possibility contemplated by the Commission in its 2021 Trade Policy 
Review Communication (COM(2021) 66 final). 

Trade agreements are a key driver of the transition to more sustainable 
food systems both in the EU and in partner countries. Modern EU trade 
agreements contain rules on trade and sustainable development, which 
require  the  effective  implementation  of  international  social  and 
several  autonomous 
environmental  commitments. In  addition, 
measures  have  been  put  in  place  since  2019  (on  deforestation,  the 
Carbon Border Adjustment Mechanism (CBAM), maximum residual 
levels of neonicotinoids, the ban on antibiotics as a growth promoter, 
corporate due diligence, etc.).  

 
 
Suggestions 

Proponents 

Assessment 

The  Commission  may  consider  to  propose,  when  necessary,  further 
targeted autonomous measures, to address global concerns, on a case-
by-case basis, in line with WTO rules, to promote the EU trade and 
sustainability agenda, while taking into account EU’s interest in stable 
trading environment as a major participant of global trade. 

Lastly,  the  EU’s  strong  position  in  multilateral  organisations  and  in 
bilateral relations with trade partners should be reinforced strategically 
to raise sustainability standards in a cooperative way. 

EU  agriculture  benefits  from  open  trade  and  free  trade  agreements. 
Agri-food  exports  drive  growth  in  the  EU  agri-food  sector,  as  the 
increase in global food consumption is occurring outside the EU. These 
exports totalled EUR 228 billion in 2023, with a positive trade balance 
of EUR 70 billion. Imports are also essential to EU agriculture, as they 
provide  crucial  intermediate  inputs  or  tropical  /  counter-seasonal 
products.  

Together,  EU  exports  and  imports  contribute  to  the  global  trade  in 
agricultural  and  food  products  and  help  balance  food  supply  and 
demand across the globe. This contributes to global food security and 
to the security of supply on the EU market, in particular if there are 
regional shortfalls in production, for example due to extreme weather 
events.  

Moreover,  free  trade  agreements  are  a  platform  for  cooperation  on 
sustainable development issues and contribute to the resilience of value 
chains by helping secure and diversify both the sources of imports and 
export destinations.  

During trade negotiations with some partners, increasing access to the 
EU  market  in  some  sectors  has  been  a  key  demand.  However,  for 
sensitive agricultural products, concessions under EU trade agreements 
are always carefully calibrated, for instance through limited tariff rate 

269 

Agriculture and free trade agreements: the EU must remove 
agriculture  from  free  trade  agreements,  and  this  must  start  by 
immediately  ending  the  negotiations  on  the  EU-Mercosur 
agreement. 

ECVC 

103 

 
 
Suggestions 

Proponents 

Assessment 

quotas  to  offer  some  access  to  our  market  and  mitigate  possible 
negative effects on sensitive products.  

the  effective 

In addition, trade agreements are a key driver for the transition to more 
sustainable  food  systems  both  in  the  EU  and  in  partner  countries. 
Modern  EU  trade agreements  contain  rules  on trade and  sustainable 
development,  which  require 
implementation  of 
international social and environmental commitments.   
The  Mercosur  free  trade  agreement  is  no  exception:  it  offers  real 
opportunities  for  EU  exporters,  in  particular  for  high  value-added 
products such as wine, olive oil and dairy products as well as one of 
the highest number of EU GIs (Geographical indications) protected in 
an  FTA.  The  FTA  will  contribute  to  securing  reliable  flows,  as 
Mercosur is already a key source of imports for the EU, in particular 
feedstuffs necessary for agriculture and tropical products such as fruits 
or coffee, for which the EU needs to rely on imports. Potential impacts 
on the EU market are mitigated through Tariff Rate Quotas phased-in 
over  long  transitional  periods,  and  for  the  first  time  in  such  an 
Agreement, protected by safeguard clauses. The negotiations are still 
on-going,  and  this  includes  an  ambitious  trade  and  sustainable 
development  chapter,  encompassing  an addendum  with  Mercosur  to 
ensure that the agreement delivers on the EU’s sustainability goals.  
Finally,  free  trade  agreements  must  be  consistent  with  WTO  rules, 
which require that parties need to establish free trade on substantially 
all the trade between the constituent territories in products originating 
in these territories.  

The Commission is finalising the  review of Commission Regulation 
(EU) No 1408/2013 (the ‘agricultural de minimis Regulation’) in light 
of the inflationary pressure in recent years and the current context with, 
amongst other things, high commodity prices affecting the agricultural 
sector. 

270 

State aid rules: call to relax State aid rules, allow for a higher 
level  of  support,  and  to  increase  and  make  the  maximum  aid 
ceiling for farmers more flexible to take into account the increase 
in  extreme  climatic  events  to  which  farmers  are  exposed 
(Commission Regulation (EU) No 1408/2013). 

State aid 

FR, MT 

104 

 
 
Suggestions 

Proponents 

Assessment 

271 

Approval  of  State  aid:  approve  State  aid  directly  within  a 
strategic  or  programme  document  (currently  within  the  CAP 
strategic plan); adopt a ‘single-window’ approach for both. 

CZ, SI 

State  aid  definitions:  unify  the  definitions  and  requirements 
laws  (e.g.  de  minimis  and 
between  different  state  aid 
GBER/ABER  legislation  for  the  definitions  of  enterprise  and 
applicant for training) 

272 

CZ, SI 

273 

reduce  certain 
for  granting  State  aid: 
Requirements 
requirements for granting State aid that create an administrative 
burden  (checks  on  an  enterprise  in  difficulty  or  limiting  non-
agricultural training only to SMEs). 

CZ 

105 

The proposal was not taken up.  In so far as funding constitutes State 
aid, its compatibility with the single market has to be assessed under 
the  applicable  State  aid  rules.  The  current  State  aid  rules  ensure  a 
balance between providing a swift basis for State aid clearance for CAP 
co-financed  measures  and  keeping 
the  necessary  competition 
safeguards. 

Lessons learned from the current period will feed into the reflection on 
the post-2027 CAP. 

The Commission is determined to address any inconsistencies that may 
exist between different pieces of legislation. The Member States are 
invited to submit their views on the existence of any inconsistencies in 
the revision process of State aid legislation. Member States are always 
closely  involved  in  this  process,  and  for  future  revisions  the 
Commission will also take into account any comments from Member 
States on potential inconsistencies. 

The proposal was not taken up. State aid rules for the agricultural sector 
recently underwent a thorough review and only entered into force in 
2023. The Commission considers that this new legal framework is fit 
for  purpose.  More  specifically,  the  exclusion  of  undertakings  in 
difficulties is a cross-cutting principle under State aid law. Given that 
their very existence is in danger, the Commission considers that aid to 
undertakings  in  difficulty  may  contribute  to  the  development  of 
economic  activities  without  adversely  affecting  trade  to  an  extent 
contrary  to  the  common  interest  only  under  very  limited  and 
exceptional circumstances and should, beyond those circumstances, be 
confined to measures in line with the conditions set out in the Rescue 
and  Restructuring  Aid  Guidelines.  On  the  limitation  of  eligible 
undertakings  to  SMEs,  it  should  be  recalled  that  State  aid  should 
address situations of market failures only. For certain types of aid, such 
a market failure only exists for SMEs, while large enterprises are able 
to carry out the relevant activities even without State aid. For training 

 
 
 
Suggestions 

Proponents 

Assessment 

274 

Exemption  for  local  action  groups  (LAGs):  request  for  the 
possibility  to  apply  the  same  exemption  for  LAGs  as  for 
municipalities  in  the  case  of  conditions  for  small  enterprises 
(Articles 60 and 61 of Commission Regulation 2022/2472/EU for 
Community Lead Local Development).  

aid,  following  an  amendment  of  the  General  Block  Exemption 
Regulation  (Commission  Regulation  (EU)  651/2014)  of  June  2023, 
training aid does not fall within the scope of the agricultural-specific 
rules anymore,  but under the  rules laid  down in that Regulation.  As 
such, training aid  is  not  limited to  SMEs but can also  be  granted to 
large enterprises. 

The proposal was not taken up.  

CZ 

Lessons learned from the current period will feed into the reflection on 
the CAP post-2027 

275 

Ceiling: setting new ceilings (300 000 EUR) for exemptions from 
the obligation to notify State aid.  

SI 

276 

277 

Project ceiling: change the ceiling of 200 000 EUR per project 
(or EUR 2 million) to facilitate international cooperation projects 
(Articles  60  and  61  of  the  ABER  for  Community  Lead  Local 
Development). 

Evaluation  of  schemes:  withdraw  the  requirement  to  conduct 
ex post evaluation of schemes with large aid budgets (a budget of 
over EUR 150 million in a given year or EUR 750 million over 
the  programme  period),  or  significantly  increase  the  applicable 
amounts, e.g. over EUR 300 million in a given year or EUR 1 500 
million over the entire programme period. 

CZ 

PL 

106 

The general definition of ‘de minimis’ was increased to EUR 300 000 
as from 1 January 2024 due to inflation in recent years.  This applies 
to the sector of processing and marketing of agricultural products, but 
not  to  primary  agricultural  production.  For  agriculture  (excluding 
marketing and processing), the Commission is finalising its review of 
the agricultural de minimis Regulation that will revise the applicable 
ceilings,  in  consultation  with  Member  States,  and  also  consulting 
stakeholders. 

The  proposal  was  not  taken  up.  The  Agricultural  Block  Exemption 
Regulation,  which  specifies  these  ceilings,  has  very  recently  been 
amended and all ceilings were adjusted to the current market situation. 
At this moment in time, therefore, the Commission does not consider 
that an increase is necessary. 

The  proposal  was  not  taken  up.  Evaluation  provides  a  means  to 
improve policy and to gather evidence on what went well and what did 
not. It is fundamental to assess effectiveness, efficiency, relevance, EU 
added  value  and  consistency  and  thus  always  improve  evidence-
gathering for the better design of a performance-based policy. 

 
 
Suggestions 

Proponents 

Assessment 

Guidelines should be provided on State aid in the agricultural and 
forestry sectors and in rural areas. 

278 

Conflict  of  interest:  call  for  clearly  defined  and  predictable 
conditions that do not allow for a broad interpretation - typically 
in the areas of conflict of interest, and reduction of administrative 
obstacles that make the setting of aid more difficult and do not 
allow flexibility in changing conditions. 

CZ 

State aid decisions provide clearance for aid, which complies with all 
the  conditions  set  in  a  decision.  Likewise,  aid  can  only  be  block-
exempted under the Agricultural Block Exemption Regulation if all the 
conditions stipulated therein are complied with. State aid decisions and 
the  Agricultural  Block  Exemption  Regulation  do  not  allow  a  wide 
margin  of  discretion.  The  conditions  are  those  clearly  stated  in  the 
notification  forms  and  in  the  national  legal  basis.  In  case  of  doubts 
when  interpretating  State  aid  rules,  Member  States  can  ask  the 
Commission  for  an  interpretation  via  the  e-State  Aid  wiki  platform. 
This platform provides transparent interpretation of rules, is accessible 
to all Member States and contributes to  greater legal certainty when 
applying State aid rules. 

Common Provision Regulation (EU) 2021/1061 

Community-Led  Local  Development  (CLLD)  support  from 
EU funds: request to increase the  upper limit for support from 
EU Funds for  CLLD (currently 25% of the total amount of the 
public  contribution  to  the  strategy,  for  costs  related  to  the 
management,  monitoring  and  evaluation  of  the  strategy  and  its 
day-to-day  running)  and  leave  it  to  each  Member  State  to 
determine the limit (Article 34 of Regulation (EU) 2021/1060 - 
Common Provision Regulation). 

CLLD  public  funding:  for  community-led  local  development, 
calculate the 25% upper limit of the total public funding for the 
support  of  running  costs  of  Local  Action  Group  (LAG) 
management and day-to-day running at Member State level and 
not at individual LAG level. 

279 

280 

LU 

AT 

107 

The added value of LEADER comes mainly from its projects, not from 
its  day-to-day  running  and  management.  In  order  to  avoid  that  too 
much of the funding goes to day-to-day running and management, an 
upper limit of 25% is considered necessary and reasonable. 

There is a relation between the projects implemented and the running 
costs of LAGs. Thus, it makes sense to apply the 25% limit at the level 
of local development strategies and not at national level. The funding 
of running costs is to support the implementation of the projects, and 
not a goal in itself. 

 
 
 
Suggestions 

Proponents 

Assessment 

281 

submission:  enable  continuous  project 
CLLD  project 
submission procedures again, not only calls for community lead 
local development. 

AT 

This matter is related to national procedures. ERDF programmes can 
provide  support  to  CLLD  strategies  where  the  Member  State  has 
included  this  option  in  the  programme  concerned.  Under  the 
responsibility  of  the  Managing  Authority  (under  the  ERDF,  or  for 
Leader  under  the  EAFRD  Authorities),  tasks  to  be  carried  out 
exclusively  by  Local  Action  Groups  include  the  preparation  and 
publication  of  calls  for  proposals.  The  relevant  provision  in  the 
Common Provisions Regulation, Article 33(3) on LAG tasks, does not 
say that calls cannot be continuously open.    

Carbon Removal Regulation – proposal COM (2022)672 

282 

Currently  in  trilogue,  but  the  regulation  only  defines  the  basic 
principles  of  certification  (similar  to  the  Renewable  Energy 
Directive). The upcoming legal acts should be designed in such a 
way to ensure that legal requirements are as clear as possible for 
the companies concerned and that the additional effort for these 
companies is minimised. 

AT 

The  certification  methodologies  are  currently  developed 
in 
consultation with an expert group. The recordings of the expert group 
meetings  and  all  its  papers  are  publicly  available.  The  Commission 
welcomes the views of all stakeholders and wants to build on existing 
best practices when developing the certification methodologies.   

CBAM (Carbon Border Adjustment Mechanism) 

283 

Amount  of  CO₂  in  fertilisers:  the  CBAM  includes  strict 
requirements on documenting the amount of CO₂ in fertiliser and 
steel/aluminium products that companies import from countries 
outside  the  EU.  This  data  can  be  very  hard  for  companies  to 
obtain. 

COPA-
COGECA 

CBAM relies on actual embedded emissions in goods imported into 
the EU, which indeed may create challenges for declarants to collect 
information  from  supply  chains.  However,  there  are  reporting 
flexibilities to address those cases where they do not manage to obtain 
information on actual emissions, such as the possibility to use default 
values. Also, Member States’ national competent authorities will take 
these  difficulties  into  account  when  deciding  whether  to  apply 
penalties. 

108 

 
 
 
 
 
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Renewable Energy (Directive (EU) 2018/2001 as amended by Directive (EU) 2023/2413) 

284 

Removal of certification: removal of certification requirements 
for biomass production in ‘low risk’ countries. 

AT 

285 

EU database for biofuels (UDB): the EU database for biofuels 
should be stopped. It creates an immense bureaucratic burden for 
the agricultural sector. For example, a large amount of data has to 
be collected from farmers by the first collectors, entered into the 
database and regularly updated. We do not see any added value 
for  the  biofuel  sector.  If  the  Commission  needs  data  on  the 
biofuels  value  chain,  it  should  use  existing  national  databases 
instead of establishing a new one 

COPA-
COGECA 

The  Renewable  Energy  Directive includes, in  Article  29 (6)  and  (7) 
sustainability  criteria  for  forest  biomass,  irrespective  of  whether  the 
biomass originates from ‘low-risk’ (the so-called ‘A-level’) countries, 
where  laws  and  regulations  are  in  place,  as  well  as  monitoring  and 
enforcement systems, or if it originates from countries where the above 
evidence is not available, and therefore management systems have to 
be in place at sourcing area level. In both cases, the Directive includes, 
in  Article  30,  rules  for  verification  of  compliance  with  the 
sustainability  and  greenhouse  gas  emissions  savings  criteria.  These 
rules  are  binding.  Some  flexibility  already  exists  for  these  low-risk 
countries,  where,  in  Article  30  (3),  the  possibility  is  given,  for  such 
cases, to use the first or second party auditing may be used up to the 
first gathering point of the forest biomass. 

In  the  context  of  ensuring  the  sustainability  of  biofuels,  the 
Commission has been mandated by the Renewable Energy Directive 
to  develop  and  put  into  operation  an  EU  database  (UDB)  as  an 
important and unique traceability tool to increase market transparency, 
mitigating the risk of irregularities or double counting of energy units 
in  the  supply  chains.  The  traceability  of  raw  materials  is  crucial  to 
ensure the traceability of the biofuels produced from them. The UDB 
is designed in such a way as to ensure that the traceability objective is 
achieved, avoiding any disproportional burden on economic operators. 

EU Regulation on Deforestation (EUDR) - Regulation (EU) 2023/1115 

286 

Implementation  of  Regulation:  suspension  or  delay  of  the 
implementation  of  the  regulation  (including  with  regard  to  the 
treatment  of  small  farmers  and  forest  owners  in  the  EU, 
documentation  and  information  system  requirements  for  ‘low’ 
versus ‘high’ risk countries, and operation of the electronic data 
transfer). 

EU farmers comply already with high standards, hence they are in a 
very  good  position  to  comply  with  EUDR  without  any  further 
excessive efforts.  

On  2  October  2024,  the  Commission  presented  a  proposal  for  an 
additional 12-month phasing-in period, which – upon agreement of co-
legislators - will shift the date of entry into application by 12 months, 

AT, SE, SK 

109 

 
 
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Legal security for agricultural and forestry work: to provide 
legal security for agricultural and forestry work (ditch cleaning, 
legal  clearance  obligations,  etc.)  it  is  proposed  to  add  the 
possibility of derogation from the EUDR to the list of derogations 
provided for in Article 16 of the Habitats Directive (92/43/EEC). 
This possibility would consist of recognising situations in which 
agricultural and forestry work is authorised by the administration, 
or regularly declared to the administration in compliance with the 
conservation objectives laid down in this Directive, and regularly 
carried out.   

Legal certainty for agricultural and forestry work: to provide 
legal certainty for agricultural and forestry work (ditch cleaning, 
legal  clearance  obligations,  etc.)  it  is  proposed  to  exempt  from 
criminal penalties infringements in the context of agricultural and 
forestry work that is regularly authorised by the administration or 
declared, and regularly carried out, by amending Article 5 of the 
Directive on the protection of the environment through criminal 
law (Directive 2008/99/EC). 

Registration  of  a  single  due  diligence  statement:  enable 
operators to register a single due diligence statement (DDS) that 
covers several consignments sent over a certain period, e.g. one 
DDS for all movements of fattened bulls or culled cows from one 
farm  to  a  slaughterhouse  per  one  year  (Article  4  of  Regulation 
(EU) 2023/1115). 

Revision  of  the  requirements  of  the  EU  Deforestation 
Regulation: a fundamental revision of the requirements of the EU 
Deforestation  Regulation 
is  needed.  The  urgently  needed 
adjustments  are:  pure  documentation  obligation  for  primary 
producers in countries with a ‘low risk’ due to demonstrably stable 
or increasing forest area in previous decades; introduction of ‘de 
minimis limits’ to continue to enable farm developments in forest-

287 

288 

289 

290 

FR 

FR 

SK 

COPA-
COGECA 

110 

to  ensure  proper  and  effective  implementation  for  all  parties  in  the 
scope of the Regulation. 

The  Commission  also  published 
the  Guidance  Document 
(C/2024/6789) and Frequently Asked Questions (FAQs) which address 
and  clarify  many  issues  raised  by  farmers  and  forest  owners.  The 
Guidance Document is divided into 11 chapters covering a diverse 
range of issues such as legality requirements, timeframe of application, 
due diligence, and clarifications on the product scope. All of these are 
supported by tangible scenarios. The document introduced flexibility 
on  the  issue  of  ‘agricultural  use’,  so  that  environmentally  respectful 
agroforestry and farming practices are promoted and not regarded as 
conflicting  with  the  EUDR,  and  that  sustainable  farming  practices  - 
such as setting aside land which is overgrown and then cleared - can 
be pursued continuously. 

The  FAQs  provide  clarification  on  the  application  of  the  rules  and 
promote  a  pragmatic  and  consistent  interpretation  of  the  regulation, 
addressing  requests  from  the  private  sector  to  have  clarifications  on 
EUDR implementation, and to simplify their work as much as possible.  

• 

It was clarified that companies do not need to file a due diligence 
statement for  every  shipment  or  batch.  One  statement  can cover 
multiple shipments and companies can do so for every contract.  
•  The  rules  for  products  containing  multiple  commodities  were 
explained (for instance, a chocolate bar containing cocoa powder, 
cocoa butter, coffee and palm oil): the operator only has to conduct 
due diligence for the products falling under the main commodity 
group.  

•  The  work  for  operators  dealing  with  bulk  commodities  was 
simplified, for example by limiting obligations for products in silos 
and by allowing operators to declare plots of land in excess.  
•  The scope of the EUDR was clarified that operators using relevant 
products  to  produce  non  relevant  products  (examples:  farmers 

 
 
Suggestions 

Proponents 

Assessment 

rich regions; development of a practical and state of the art EU 
information system; disclosure of a reference number instead of 
all information in the due diligence declaration; and extension of 
the  implementation  deadline  for  Member  States  until  a  revised 
regulation is published.  

growing  soy  to  feed  their  poultry)  are  outside  the  scope  of  the 
EUDR.  Simplification  efforts  also  focused  on  the  scope:  cattle 
animals born before the entry into force are not in scope and are 
not subject to the requirements.  
It was clarified that operators and traders are not made liable for 
forest degradation that takes place after they have placed relevant 
products on the EU market. 

• 

Proposal for a directive on Soil Monitoring and Resilience (Soil Monitoring Law), COM(2023) 416 

291  Technical  annexes:  amendment  of  the  proposal  as  regards 

Articles 6 to 8 and technical annexes I, II and III. 

IT 

292 

Monitoring and mapping: the new obligation for monitoring and 
mapping  of  all  contaminated  soil  should  not  impose  an 
administrative  burden  on  farmers.  It  is  difficult  to  identify  a 
polluter  of  contaminated  soils.  Problem  of 
involuntary 
contamination as a result of farming practices (e.g. building up of 
pesticides residues over time). 

MT 

293 

Administrative  burden:  comments  on  significant  efforts 
involved in implementing the future legislation at Member State 
level and/or general request to limit the administrative burden in 
developing the legislation. 

AT, BE 

The  ordinary  legislative  procedure  for  this  file  is  currently  ongoing. 
The  European  Parliament  approved  its  first  reading  position  on  10 
April 2024, while the Council has adopted its general approach on 17 
June  2024.  The  trilogues for  the  Soil  Monitoring  Law  started  on  22 
October 2024.  

The proposal aims to put in place a solid and coherent soil monitoring 
framework for all soils across the EU and to continuously improve soil 
health with the aim of achieving healthy soils by 2050. The proposed 
Directive therefore lays down measures on monitoring and assessment 
of soil health, sustainable soil management and contaminated sites. 

Under the Soil Deal for Europe mission, a few projects have been put 
in  place  to  better  identify  indicators  and  to  provide  support  to  the 
national  bodies  to  update  and  develop  adequate  methodology  for 
monitoring. The Commission’s Joint Research Centre will work to this 
end in cooperation with researchers and national authorities. 

294 

Use of fertilisers: reduction of administrative burdens related to 
the use of fertilisers containing nitrogen in rock and the control of 
their use. 

PL 

An  evaluation  of  the  Nitrates  Directive  is  ongoing.  The  precise 
application of the Directive depends on national rules, which may be 
reviewed  by  the  national  authorities  while  ensuring  the  overall 
effectiveness of their national nitrate action programme. 

Nitrates Directive (91/676/EEC) 

111 

 
 
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Assessment 

295 

RENURE  products:  RENURE  (recovered  nitrogen  from 
manure)  products  should  be  recognized  as  fertilisers  instead  of 
continuing to be labelled as ‘animal manure’.  

BE 

296 

RENURE:  allow  for  a  temporary  exemption  from  the  Nitrates 
Directive limit, in the short term, so that the safe use of RENURE 
products  is  allowed  above  the  limit  of  170  kg  of  nitrogen  per 
hectare per year in specific areas, based on the RENURE criteria 
developed  by  the  Commission’s  Joint  Research  Centre,  and 
propose a revision of Annex III of the Nitrates Directives to allow 
for  a  permanent  exemption  of  RENURE  products  from  the 
Nitrates Directive limit in the medium term. 

COPA-
COGECA 

On  19  April  2024  the  Commission  presented  a  draft  Commission 
Directive amending Annex III of the Nitrates Directive in this respect. 
The  draft  act  is  pending  the  opinion  of  the  Member  States  in  the 
Nitrates  Committee  and  the  scrutiny  of  the  co-legislators  before 
coming into law. An evaluation of the Nitrates Directive is ongoing, 
which  will  further  analyse  the  role  of  different  forms  of  organic 
fertilisers under the Directive. 

Proposal for a Forest monitoring regulation, COM(2023) 728 

297 

Data collection: the law is not needed as Member States already 
have  monitoring  systems.  Questions  on  the  purpose  of  data 
collection. Issues of data protection. 

298 

Forest management plan: concerns about the extensive contents 
of a ‘reforestation plan’. Owners of forests up to 100 ha should be 
exempted  from  the  obligation  to  draw  up  a  forest  management 
plan.  The  requirement  for  a  climate  benefit  analysis  should  be 
removed 

Information on forest is patchy and uncoordinated and does not make 
it  possible  to  check  the  impact  of  legislation  nor  to  ensure  forest 
resilience  in  a  changing  environment.  This  proposal  does  not  go 
beyond  what  is  necessary  in  order  to  achieve  that  objective  and  it 
should  therefore  be  maintained.  In  particular  it  builds  on  existing 
national  systems  by  promoting  harmonisation  and  it  complements 
them by providing standardised data though Earth observation. It also 
includes safeguards on data protection.  

The  proposal  does  not  include  requirements  for  forest  management 
plans. It is up to the Member States to decide the threshold for these 
plans and their content. 

AT 

AT  

Proposal for a Nature Restoration Law, COM(2022) 304 

299 

Mandatory  indicators:  reduce  the  number  of  mandatory 
indicators  and  remove  or  make  optional  the  ‘woodland  index’ 
indicator. 

AT 

112 

Following the positive vote in the European Parliament, the Council 
approved the Nature Restauration Law (NRL) on 17 June 2024, which 
ended the ordinary legislative procedure.  

 
 
 
Suggestions 

Proponents 

Assessment 

300 

Agricultural  ecosystems:  eliminate  provisions  relating 
agricultural ecosystems (Article 11 of the proposal). 

to 

IT 

The adopted act was published in the Official Journal of the EU on 29 
June 2024 (Regulation (EU) 2024/1991). 

301 

Requirements  of 
the  Nature  Restoration  Regulation: 
the  Nature 
fundamental  revision  of 
Restoration Regulation needed to ensure that any additional EU 
requirements are also financed with additional EU funds outside 
the CAP and do not counteract the objective of food and supply 
security. 

the  requirements  of 

COPA-
COGECA 

The Regulation cannot and does not prejudge the prerogatives of co-
legislators for the adoption of the MFF post-2027. 

Industrial Emissions Directive (revised Directive 2010/75/EU) 

302 

No expansion of scope: the transitional provisions should ensure 
that  already  existing  livestock  buildings  are  not  affected  by  the 
new requirements under the Industrial Emissions Directive (IED). 
The scope of application should not be expanded. 

COPA-
COGECA 

303 

Reporting  requirements:  all  major  companies  in  the  food 
industry  (slaughterhouses,  dairies,  biogas  plants,  etc.)  and 
livestock  farms  (pigs  and  chickens)  will  now  be  subject  to 
requirements  to  reporting  in  a  comprehensive  environmental 
management  system.  For  various  industries,  there  will  be 
requirements  for many  sub-management systems (often  6 to  8). 
For  example,  slaughterhouses  must  have  specific  management 
systems for water, energy, chemicals, odour, noise, refrigeration, 
and  abnormal  operation,  in  addition  to  a  general  environmental 
the 
management  system.  This  will  significantly 
to 
administrative 
environmental improvements. 

increase 
proportional 

burden  without 

being 

COPA-
COGECA 

113 

The legislative process on the revised  IED has been completed. The 
revised Directive contains certain extensions of scope as a result of the 
co-decision procedure. 

The document containing the detailed technical requirements (uniform 
conditions for operating rules) will be prepared in the near future in an 
inclusive  process  with  operators,  Member  States  and  other 
stakeholders and will take into account the difference between existing 
and new installations where relevant. 

The  revised  IED  does  not  significantly  increase  the  administrative 
burden on the agricultural sector. It does not include an environmental 
management system requirement for pig and poultry farms.   

The requirement to implement an environmental management system 
for  slaughterhouses  was  laid  down  in  Commission  Implementing 
Decision  (EU)  2023/2749  establishing  best  available  techniques 
conclusions  (BAT  conclusions)  for  slaughterhouses,  animal  by-
products and/or the edible co-products industries.    

For  dairies,  such  a  requirement  was  introduced  by  Commission 
establishing  BAT 
Implementing  Decision 
conclusions for the food, drink and milk industries.  

(EU)  2019/2031 

 
 
Suggestions 

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Assessment 

304 

Best  available  techniques  (BAT):  new  BAT  conclusions  for 
individual 
industries  continuously  set  more  measurement 
requirements  for  pollutants  with  increased  frequency.  All  these 
additional  measurements  must  be  reported  to  the  authorities, 
regardless  of  whether  the  measurements  are  stable  over  days, 
months or years. This leads to increased administrative costs. 

COPA-
COGECA 

305 

Link with the Nitrates Directive: formal clarification sought that 
farms that comply with the requirements of the Nitrates Directive 
due to their area-based livestock farming system do not fall within 
the scope of the IED, regardless of the number of livestock units. 

COPA-
COGECA 

The above documents are from 2019 and 2023 and are therefore based 
on the existing Directive.  

Moreover,  according  to  these  documents,  the  management  plans 
covering various aspects (energy, noise, etc.) are all part of the same 
environmental  management  system,  which  aims  at  covering  all 
environmental impacts. 

The  revised  IED  allows  the  use  of  emission  factors  instead  of 
measurements for pig and poultry farms where relevant.  

This approach was also possible under the existing Directive.  

Moreover,  BAT  conclusions  account  for  cases  where  measurements 
are  stable  and  give  the  option  for  less  frequent  monitoring  in  such 
cases,  thus  allowing  a  proportionate  monitoring  (see  for  example 
footnote  4  of  BAT  4  of  Commission  Implementing  Decision  (EU) 
2019/2031 establishing BAT conclusions for the food, drink and milk 
industries). 

The Nitrates Directive does not ensure a comprehensive assessment of 
emissions to air, water and soil of the installations on livestock farms, 
but is only concerned with the land application of manure and fertiliser 
and with the presence of sufficient storage capacity for manure. For 
large  installations  there  is  still  a  need  for  an  integrated  approach  to 
pollution prevention and emissions control to air, water and soil in line 
with the IED. 

114 

 
 
 
 
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Assessment 

306 

307 

308 

309 

CSDDD (Corporate Sustainability Due Diligence Directive, Directive (EU) 2024/1760) 

Clarification necessary: key terms, including ‘value chain’ and 
‘business  relationship’  must  be  clarified,  to  ensure  that  human 
rights,  environmental  and  climate-related  due  diligence 
requirements  are  only  applicable  and  enforceable  where 
companies have the legal or factual ability to influence the value 
chains they operate in, including the downstream sector.  

COPA-
COGECA 

The coverage of the downstream value chain in the final version of the 
Directive has been limited to value chain partners that operate ‘for or 
on  behalf  of’  the  large  company  in  question.  This  ensures  that  only 
those  business  relationships  over  which  the  company  has  factual 
control are covered.   

Importance  of  legal  certainty:  attention  must  be  paid  to 
guidelines and delegated acts, to ensure they do not lead to further 
fragmentation and undue burdens on companies.  

COPA-
COGECA 

Several  safeguards  have  been  introduced  in  the  final  version  of  the 
Directive  to  ensure  that  the  delegated  acts  do  not  lead  to  further 
fragmentation and undue burdens.   

Restricted scope of affected parties: to achieve legal certainty 
and  avoid  undue  burdens  on  companies,  this  scope  must  be 
limited to those genuinely affected by adverse impacts set out in 
this Directive, to avoid the risk of mass litigation by parties that 
are not genuinely affected stakeholders. 
Director’s duties provision: the provision on directors’ duties is 
not  necessary  to  achieve  the  aims  of  this  directive.  Such  a 
provision  would  have  negative  impacts  on cooperatives,  which 
differ  from  other  companies  as  regards  the  roles  of  their 
governance  bodies  and  management,  their  role  in  the  social 
economy, and the different relationship the farmer-members have 
toward their cooperatives compared to the relationship between a 
shareholder and a limited company 

COPA-
COGECA 

The definition of stakeholders has been limited to affected stakeholders 
and  it  is  only these  affected  stakeholders  who  have  rights  under the 
final version of the Directive. 

COPA-
COGECA 

All  directors’  duties  have  been  deleted  in  the  final  version  of  the 
Directive. 

Reporting under the CSRD Directive (Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464) 

Voluntary  standards:  introduce  voluntary  standards  for  non-
listed SMEs – such standards must be treated as a ceiling and take 
into consideration the very limited capacities of SMEs to dedicate 
resources to sustainability reporting.  

310 

COPA-
COGECA 

Sector  standards:  the  current  NACE  codes are  concerning,  as 
products  can  end  up  under  different  sectorial  standards.  Care 

Voluntary standards for non-listed SMEs: the Commission expects 
to publish such standards next year, taking account of the capacities 
and resources of SMEs.  

Sector standards: the Commission will consider how to proceed with 
the development of sector standards. 

115 

 
 
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Assessment 

must  be  taken  to  avoid  introducing  unnecessary  administrative 
complexities in the value chain.  

Ensure  that  there  is  alignment  between  SME  standards  and 
sectoral standards.   

Many  of  the  metrics  in  the  standards  are  unclear  and  poorly 
defined in the environmental context. 

Risk of double reporting: there is a lack of consistency between 
current  reporting  at  the  company  level  under  the  EU's 
environmental regulation and CSRD reporting.   

There is a revision of reporting at the company level under the 
EU's  environmental  regulation  (the  new  European  Industrial 
Emissions  Portal)  without  it  being  coordinated  with  CSRD 
reporting.  

Increased costs for auditing sustainability reporting.  

Overall, the above contributions are seen to lead to significant 
costs and a lot of hassle for businesses. 

Alignment  between  SME  standards  and  sector  standards:  The 
Commission and the  European  Financial  Reporting Advisory  Group 
(EFRAG) will ensure adequate links between these two dimensions.   
Metrics:  EFRAG  has  established  an  online  Q&A  platform  where 
companies  can  ask  for  specific  advice.  EFRAG  can  also  publish 
additional implementation guidance.  
Consistency  with  EU  environmental  legislation:  EFRAG  and  the 
Commission took care to ensure adequate consistency but remain open 
to examine specific issues if they are highlighted by stakeholders.   
Industrial Emissions Portal: data on the environmental impacts of the 
biggest  European  industrial  installations  have  been  reported  by 
economic  operators  and  published  for  more  than  15  years  under 
Regulation  (EC)  166/2006  and,  as  from  2028,  under  the  IEPR 
(Regulation  (EU)  2024/1244  repealing  the  E-PRTR).  This  data  will 
serve  companies  as  a  robust  source  of  information  when  preparing 
consolidated reports under the CSRD. The Regulation introduces an 
option for a simplified reporting for livestock and aquaculture sectors 
to reduce the reporting burden. 
Audit:  the  co-legislators  decided  in  the  CSRD  that  sustainability 
reporting should be subject to assurance (audit) and this indeed implies 
costs for companies.  However, the Directive starts with a lower and 
less costly level of assurance (limited assurance’), moving only to a 
higher  level  of  assurance  (‘reasonable  assurance’)  after  a  feasibility 
assessment.   
Overall: the Commission has taken measures to assist companies and 
ensure proportionality: the thresholds to define large companies have 
been raised, with the effect that the number of companies subject to the 
requirements  is  reduced  by  about  14%;  the  Council  and  Parliament 
agreed with the Commission proposal to postpone adoption of a first 
set of sector standards to mid-2026; the Commission modified the draft 
standards submitted by EFRAG, for example adding some additional 
phase-ins  provisions  and  making  some  disclosures  voluntary;  the 
the  development  of 
Commission  asked  EFRAG 

to  prioritise 

116 

 
 
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Assessment 

implementation  guidance  for  companies;  and  the  Commission  is 
launching  a  new  flagship  technical  support  instrument  to  assist 
Member States in supporting companies with implementation. 

Proposal for a Green Claims Directive  (COM(2023)166 final) 

311 

312 

Verification  of  environmental  measures:  the  Green  Claims 
Directive  can  create  a  potential  administrative  burden  at  farm 
level.  In  fact,  the  CAP  is  not  excluded,  nor  the  voluntary 
additional efforts (eco-schemes) that can be done at farm level. If 
a  farmer  or  a  trader  decides  to  (voluntarily)  communicate  on 
some environmental aspect of production (such as the benefits of 
a measure implemented under an eco-scheme), the farmer risks 
going through a double verification (under CAP and under Green 
Claims).  There  is  a  need  to  make  sure  that  verification  of 
environmental measures is done only once. 

COPA-
COGECA 

This specific issue is under discussion by the co-legislators as part of 
the co-decision process. 

Plant health, Plant protection products 

Electronic  recording  of  plant  protection  products  (PPP): 
reduce the  administrative burden  associated  with the  electronic 
recording  of  plant  protection  products  (PPP),  laid  down  in 
Commission Implementing Regulation (EU) 2023/564 as regards 
the content and format of the records of plant protection products 
kept by professional users.  

Proposal  for  postponing,  phasing  in  or  testing  through  a  pilot 
scheme the implementation of electronic recording of the use of 
PPP until 2026, including of the application of the requirement to 
identify the location or facility through geospatial aid application 
of the IACS system.  

CY, FI, LU, 
PL 

The proposal was not taken up. The timing for keeping records on the 
use  of  plant  protection  products  (which  has  existed  since  2009)  in 
electronic  format  was  extensively  discussed  prior  to  adoption  of 
Commission  Implementing  Regulation  (EU)  2023/564.  The  longest 
possible  time  frame  has  been  chosen  to  enable  Member  States  to 
comply  with  their  reporting  obligation  under  Regulation  (EU) 
2022/2379  on  Statistics  on  Agricultural  Input  and  Output  (SAIO). 
Delaying  electronic  records  further  would  create  difficulties  for 
Member State authorities to collect and report the records as required 
by SAIO. 

313 

Plant  protection  products  applications  based  on  geodata: 
deletion of the obligation to specify the plant protection products 
in the geodata-based application; also, deletion of the obligation 
to do this electronically. 

AT 

Inclusion of PPP in the geodata-based application is an option that 
Member States can use, not an obligation.  

117 

 
 
 
Suggestions 

Proponents 

Assessment 

COPA-
COGECA 

Authorisation  procedures:  faster  authorisation  procedures  for 
market access of new active substances (without compromising 
the safety of the products). 

COPA-
COGECA 

Regulation (EC) No 1107/2009 already contains clear deadlines for the 
various pre-marketing procedures, which are, however, in many cases 
not  respected  by  the  Member  States  due  to  resource  constraints.  
The Commission has already repeatedly reminded Member States (and 
will continue to do so) to increase resources and respect deadlines and 
it has provided financial support to Member States for this purpose. 

FR 

The  Commission,  in  consultation  with  the  Member  States,  is 
considering the matter. As an interim approach, such treated seeds are 
handled as a mixture when exported. 

314 

315 

316 

Status of seeds: clarify the status of seeds treated with a plant 
protection product (mixture or an item/an article) in the context 
of their export (Regulation (EU) 649/2012). 
Maximum limits on residues: simplification of the lowering of 
the maximum limits on residues for prohibited plant protection 
substances The lowering of maximum residue levels (MRLs) for 
pesticide residues could become systematic after the end of the 
approval  of  a  plant  protection  product  and  the  expiry  of  grace 
periods,  at  least  for  all  substances  presenting  an  exclusion 
criterion for human health or for which the level of risk cannot be 
properly  assessed  due  to  the  absence  of  an  update  of  the 
toxicological  dossier  (Regulation  (EU) 
  and 
Regulation (EC)  396/2005 ). 

  1107/2009 

FR, HU 

Lowering MRLs for substances after the expiry of approval and grace 
periods  is  already  current  practice.  Existing  Codex  MRLs  must  be 
considered  in  line  with  the  EU's  international  obligations,  and  a 
targeted  risk  assessment  by  the  European  Food  Safety  Authority 
(EFSA) is needed in most cases. Such a risk assessment is also needed 
to  see  whether  the  toxicological  dossier  is  outdated  and,  therefore, 
whether the toxicological reference values are no longer appropriate. 
This is not always the case. 

The availability and placing on the market of alternatives  to PPPs is 
indeed an important element in the shift to a more sustainable use of 
PPPs.  

The decisions on approval of active substances and/or authorisation of 
PPPs must be taken in the light of the outcome of a risk assessment to 
prevent risks to human health or the environment.  

The  Commission  has  called  multiple  times  on  Member  States  to 
low-risk  and 
accelerate 
biologically active substances and products to increase the availability 
of such products to farmers. 

the  assessment  procedures  for  new, 

317 

Alternatives  for  plant  protection  products:  alternatives  to 
plant protection products must be available on the market before 
PPPs are withdrawn or banned.  

MT 

118 

 
 
Suggestions 

Proponents 

Assessment 

318 

Temperature of melting ice: definition of the range temperature 
corresponding to the temperature of melting ice to facilitate trade 
between  Member  States  for  fishery  products  (Regulation  (EU) 
2004/853). 

EL 

The international standard refers to the temperature of melting ice. The 
Commission is not aware of any trade issues linked to this provision. 

Hygiene requirements for food of animal origin 

The  Commission  also  provides  financial  support  to  Member  States 
(EUR 10 million over 5 years) and training to increase the capacity and 
expertise to conduct such assessments.   

319 

Approval  of  wild  game  collection  centres:  withdraw  the 
requirement  to  approve  wild  game  collection  centres  receiving 
venison from other wild game collection centres.  

Explanation:  These  are  establishments  where  no  handling  of 
product is allowed. The health approval process is complex for 
these  primary  producers,  knowing  that  no  health  mark  can  be 
applied to carcasses covered in hair or feathers which have not 
been checked by veterinary inspection services (Regulation (EC)  
853/2004,  Annex  III,  Section  IV,  Chapter  II,  Point  10  and 
Regulation (EC)  853/2004,  Annex III, Section IV, Chapter III, 
Point 8). 

320 

Authorisation of exceptional carcasses: remove the process of 
authorising  the  transport  of  ‘exceptional  carcasses’  (carcasses 
leaving slaughterhouses with a core temperature above 7°C).  
Explanation:  to  transport  ‘exceptional  carcasses’,  transporters 
must  have  a  written  authorisation  issued  by  the  competent 
authority. This means that each time ‘exceptional carcasses’ are 

FR 

FR 

119 

In  accordance  with  Article  4(2)  of  Regulation  (EC)  853/2004, 
establishments handling products of animal origin need approval, with 
some exceptions e.g. primary production.  

Primary  production  means  only  the  activity  of  producing  primary 
products. To avoid burdening primary producers, other activities that 
are not primary production are considered ‘associated operations’ only 
if the primary producers do carry them out.  

Therefore,  to  consider  the  first  collection  centre  where  the  hunted 
animals arrive as primary production (no approval), is already a very 
flexible interpretation of the definition which is currently applied.  

A collection centre collecting wild game from other collection centres 
does not carry out primary production and must therefore be approved. 
However, there is no limit to the number of collecting centres which 
may supply the ‘approved’ or ‘registered’ collecting centre. 

Amendments  to  Article  4  of  Regulation  (EC)  No  853/2204  would 
require an ordinary legislative procedure. 

Point 3(b) of Chapter VII to Section I of Annex III to Regulation (EC) 
853/2004 already allows carcasses, half carcasses or half carcasses cut 
into three wholesale cuts, to leave the slaughterhouse before the core 
temperature  of  7°C  is  reached  (Amendment  by  Regulation  (EU) 
2017/1981).  This  additional  flexibility  was  introduced  based  on  an 

 
 
Suggestions 

Proponents 

Assessment 

loaded,  the  competent  authority  must  be  present  to  issue  these 
written authorisations. Loadings are often carried out outside the 
slaughterhouse's operating hours, when the veterinary inspection 
service is  not  present.  This  authorisation therefore represents  a 
significant  logistical  obstacle  to  the  free  movement  of  goods, 
knowing that an authorisation has already been issued in advance 
to the slaughterhouse to remove these ‘exceptional carcasses’. 

321 

Health standards: differentiated health standards depending on 
the  destination  of  the  animal  product:  export,  national  and/or 
short  circuit;  financial  and  administrative  support,  small  milk-
processing  units,  butcheries  and  other  animal  production 
facilities.  

ECVC 

72 https://www.efsa.europa.eu/en/efsajournal/pub/3601 

120 

EFSA  opinion72.  The  EFSA  opinion  provided  combinations  of 
maximum surface temperatures at loading, and maximum chilling and 
transport times that result in the same microbiological safety as a core 
temperature of 7°C. 

Increasing  the  core  temperature  without  considering  the  other 
conditions laid down in the Regulation will increase pathogen growth. 

To  avoid  any  food  safety  issue  from  the  transport  of  ‘exceptional 
carcasses’, a certain level of control by the competent authorities in the 
slaughterhouse needs to be ensured until the safe temperatures of the 
carcasses has been reached. 
 Health standards and risk mitigation measures, including biosecurity, 
are  based  on  science  (risk  assessment)  and  aligned  with  SPS 
international standards regardless of the size or commercial vocation 
of farm.  

EU  Harmonised  rules  apply  across  the  EU,  whether  the  product  is 
destined for export or for trade within the EU, covering the hygiene of 
foodstuffs and the production and placing on the market of products of 
animal origin applicable to all food and all food operators right through 
the  food  chain  ("from  farm  to  fork"),  together  with  effective 
instruments  to  manage  food  safety  and  any  future  food  crises 
throughout  the  food  chain.  Specific  rules  are  applicable  for  primary 
production, and these are less burdensome already if compared to those 
addressing other businesses in the food chain. 

Exporting countries may have additional conditions. The Commission 
or Member States address these via export certificates. Companies in 
Member  States  decide  if  they  want  to  participate  and  meet  these 
conditions. Having different export certificates based on type and size 
of operators (farms/companies) is impractical. 

 
 
 
 
Suggestions 

Proponents 

Assessment 

Feed / animal by-products 

322 

Upcycle  of  waste:  upcycling  of  waste  and  the  introduction  of 
new  feed  sources  to  develop  sustainable  and  circular  feed 
production in the EU.  

Proposal:  a  more  integrated  approach  between  transmissible 
spongiform encephalopathy (TSE) legislation and feed hygiene 
legislation; a revision of the current EU rules,  including lifting 
the  current  feed  ban  in  the  TSE  legislation,  in  the  animal  by-
products  legislation,  and  in  the  feed  marketing  legislation  to 
allow for more protein feed of animal origin on the market. 

Lifting feed bans to facilitate the use of insects as a potential 
new feed source; scientifically assess the risks of using catering 
waste;  allow more chemical  phosphorous  substances  of  animal 
origin as animal feed.   

DK 

This is a significant change to the basic rules that cannot be envisaged 
before scientific advice is obtained and further discussion takes place.  

The feed ban is the basic preventive measure against TSE and consists 
of  a  ban  on  the  use  of  processed  animal  protein  (PAP)  in  feed  for 
farmed animals. The EU feed ban provisions are reviewed regularly 
based  on  EFSA  opinions  and  the  development  of  new  analytical 
methods  for  official  controls.  The  feeding  of  ruminants  with  any 
animal-derived protein is and must remain prohibited, as it was at the 
origin  of  the  bovine  spongiform  encephalopathy  (BSE)  epidemic, 
which has been detrimental to the meat sector for decades mainly due 
to  the  consumer  perception  that  ruminants  became  carnivores.  In 
September  2021,  a  significant  relaxation  of  the  feed  ban  rules  was 
adopted with the authorisation to use PAP derived from pigs and 

121 

 
 
Suggestions 

Proponents 

Assessment 

 insects in poultry feed and PAP derived from poultry and insects in 
pig feed. PAP derived from insects is therefore already authorised in 
the feeding of all major farmed animal species (except ruminants) and 
pet and fur animals. These measures already allowed a wider use in 
feed  of  high-quality  protein  derived  from  pigs,  poultry  and  insects, 
which are locally produced in the EU, partially substituting soybean 
imported from the Americas and contributing to a more level playing 
field for European farmers. In addition, the use of di- and tricalcium 
phosphate of animal origin is already broadly authorised in the feeding 
of all animal species except ruminants.  
The feed ban is supplemented by the prohibition of cannibalism laid 
down in the Animal By-products Regulation 1069/2009.  
Insects  are  feed-producing  animals  and  subject  to  risk  mitigation 
measures for the prevention of animal health risks posed by feed. The 
Commission is in close contact with the stakeholder organisations of 
the feed industry, which are developing new technology for the safe 
use  of  new  feeding  substrates  for  insects,  including  feeding  from 
catering waste. When a new technology is developed, it will need be 
subject to the EFSA risk assessment before any change in legislation 
might be envisaged. 

Feed additives are important for the competitiveness of EU farmers and 
the  sustainability  of  the  climate  and  the  environment,  given  their 
potential to improve nutrient intake.  
Certain additives enable a reduction in methane emissions. This will 
be  one  of  the  main  building  blocks  of  the  EU’s  response  to  curb 
emissions  form  livestock,  supported  by  research  and  innovation 
funding and projects.  
The  outcome  of  the  evaluation  of  Regulation  (EC)  1831/2003 
published  by  the  Commission  on  28  February  2024 did  not identify 
major issues. However, reflections on possible improvements are 

323 

Revision of the feed additive regulation: in connection with the 
revision  of  Regulations  (EC)  1831/2003  and  429/2008,  the 
Commission is invited to speed up the authorisation of innovative 
feed  additives,  clarify  requirements  and  provide  guidance  on 
endpoints.  Rules  on  sustainability  claims  should  preferably  be 
introduced as well. There is a need to improve the current system 
for the application for authorisation for all types of feed additives, 
for all relevant animal species. The possibility of extending the 
authorisation period for certain feed additives beyond the current 
10 years, or making the authorisation permanent for certain feed   

DK 

122 

 
 
 
 
 
 
Suggestions 

Proponents 

Assessment 

additives, should be considered without compromising safety and 
consumer protection. 

324 

Food waste and food safety: repeal EU legislation that has no 
added  value  for  food  safety:  rules  that  prohibit  the  feeding  of 
kitchen waste, food scraps, manure and category 2 offal, and the 
rules  that  prohibit  feeding  manure  (relevant  for  insects) 
(Regulation  (EC)    1069/2009,  Regulation  (EU)  142/2011  and 
Regulation (EC). 767/2009). 

NL 

325 

(EU)  2023/361 

Highly  Pathogenic  Avian  Influenza  (HPAI)  vaccination: 
(Highly 
proposal  concerning  Regulation 
Pathogenic  Avian  Influenza  -  HPAI  vaccination).  While 
vaccination  against  HPAI  is  an  effective  tool  for  reducing  the 
risks of spreading the virus, it is desirable to allow farms that have 
scheduled preventive vaccination to carry it out, even in restricted 
areas. However, farms that have not committed to a vaccination 
schedule before the date of confirmation of the outbreak will not 
be allowed to use preventive vaccination in restricted areas. 

Animal Health 

FR 

123 

ongoing. The Commission is prepared to work with Member States to 
provide clarity on the requirements and procedures as needed, keeping 
in mind that EFSA provides its own guidance on safety and efficacy 
assessments of feed additives.  

In  the  meantime,  the  Commission  will  continue  to  process  the 
numerous requests for feed additives authorisations to improve market 
access for companies, and the existing legal framework is to be used to 
its full extent to support innovation, in particular as regards sustainable 
feed additives. 
Both  recently  and  in  the  past  there  are  many  examples  of  animal 
disease outbreaks in the EU (e.g. ASF in Portugal) which were further 
spread because catering waste was fed to animals. Manure and other 
animal  by-products  of  category  2  material  also  present  significant 
health risks. For this reason, the prohibition on feeding kitchen waste 
to  animals  should  remain  in  place,  in  particular  for  the  purpose  of 
ensuring animal health. 
Any  change  to  those  rules  can  only  be  made  after  a  thorough  risk 
assessment. 

The  proposal  was  not  taken  up.  EU  rules  on  HPAI  vaccination  are 
recent  (Regulation  (EU)  2023/361)  and  are  modern,  proportionate, 
based on science (EFSA) and aligned to international standards (World 
Organisation  for  Animal  Health).  The  differentiation  between 
measures  applied  under  preventive  vaccination  and  emergency 
vaccination needs to be kept. Future amendment to EU rules can only 
be envisaged after new science (EFSA) and experience is gained on 
use of vaccination under these two scenarios.  

 
 
 
 
 
Suggestions 

Proponents 

Assessment 

(HEH):  following 

(EU)  2020/688,  which 

Epizootic  haemorrhagic  disease 
the 
emergence  of  the  HEH  in  Europe  in  2022,  the  Commission 
amended  Regulation 
introduced 
derogation  conditions  (for  vector-protected  establishments  or 
seasonally free zones) for movements between Member States, in 
case of HEH outbreaks. 
The  derogation  conditions  do  not  provide 
the  expected 
operational solutions. They are not applicable in Member States 
in southern Europe which do not have a vector inactivity period 
and  are  poorly  adapted  to  extensive  livestock  farming  (vector-
protected  establishment).  The  other  option  offered  in  the 
Regulation  is  to  accept  all  animals  ‘unconditionally’  and  to 
inform the Commission of this, which amounts to allowing some 
countries to deregulate the disease, and to enabling its spread to 
other Member States, which is contrary to the very spirit of the 
LSA. 
Proposal:  a new amendment to the provisions of Regulation (EU) 
No  2020/688  so  as  not  to  block  trade,  which  has  an  important 
economic impact on the Member States. 

Quarantine  pests:  simplification  of 
the 
administrative procedure for EU co-financing of actions against 
quarantine pests. Revision of mandatory elements of veterinary 
programmes due to an increase in costs borne by the authorities 
and  the  reduction  of  EU  co-financing  (Regulations  (EU) 
2016/429 and (EU) 2021/690). 

the  steps 

in 

326 

327 

FR 

EU rules on Epizootic Haemorrhagic disease (EHD) are limited to: (i) 
surveillance  and  notification;  (ii)  preventing  the  disease  from 
spreading  on  account  of  movements  of  animals  between  Member 
States or from third countries.  
EU  rules on  vaccination  are  being laid down to take account of  the 
imminent  availability  of  new  vaccines  together  with  some  other 
optional  risk-mitigating  measures. 
  The  relevant  Commission 
Delegated Regulation (C(2024)6985) was adopted by the Commission 
on  9  October  2024  and  is currently under  scrutiny  by  the  European 
Parliament and the Council. 

More substantial amendments to EU rules, if appropriate, can only be 
envisaged after new science has been developed (requiring an EFSA 
assessment) and experience has been gained.  

As  regards  veterinary  programmes,  Regulation  (EU)  2016/429  and 
supplementing legislation (chiefly Commission Delegated Regulation 
(EU)  2020/689)  lay  down  the  minimum  basic  requirements  for  the 
control and  eradication  of  certain  animal  diseases  through  the 
implementation of EU-approved programmes.  

scientific 

The  requirements  are  technical  aspects  based  on  international 
standards, 
They 
include surveillance,  movement  control,  vaccination,  and  disease 
control measures.  Regardless of the possible EU co-financing of those 
programmes, they cannot be subject to simplification as they are the 
minimum necessary for the proper control of certain animal diseases. 

experience. 

advice, 

and 

FR, HU 

124 

 
 
 
 
Suggestions 

Proponents 

Assessment 

(Regulation 

(EU)  2021/690)  enables 

EU  co-financing 
the 
reimbursement  of  eligible  expenses  incurred  by  Member  State 
authorities to implement those veterinary programmes. As amount of 
EU funding for veterinary programmes is limited, Member States have 
to finance the remainder of the costs. 
Regulation (EU) 2019/6 was published in January 2019. The stepwise 
approach  provided  for  in  its  Article  57  aims  at  providing  Member 
States with sufficient time to put in place data collection systems: i) by 
January 2024, for the species and categories included in Commission 
Implementing  Decision  2013/652/EU;  (ii)  by  January  2027,  for  all 
food-producing  animal  species;  (iii)  by  January  2030,  for  other 
animals which are bred or kept. 

328 

Data  collection  on  veterinary  medicinal  products:  delay  the 
mandatory  data  collection  by  Member  States  of  the  use  of 
antimicrobial  veterinary  medicinal  products  until  2027 
(Regulation (EU) 2019/6).  

LV 

Commission Delegated Regulation (EU) 2021/578 (published in April 
2021)  provided  Member  States  with  the  requirements  for  the  data 
collection. Under the single market programme, the Commission has 
also provided support to Member States (through multiannual grants) 
to put in place and operationalise such systems (Latvia being one of 
the  beneficiaries).  Therefore,  the  requested  delay  until  2027  of  the 
submission of use data seems difficult to justify.  

Commission  Delegated  Regulation  (EU)  2021/578  provides  a 
framework  for  Member  States  to  decide  how  to  organise  such  data 
collection  at  national  level.  Article  13(1)(a)  provides  that  Member 
States  shall  collect  those  data  from  the  following  data  providers,  as 
appropriate: veterinarians, retailers, pharmacies, feed mills and end-
users, including farmers or breeders. Therefore, Member States may 
consider collecting the data from possible providers other than farmers 
to avoid an administrative burden on farmers. 

125 

 
 
 
 
 
 
 
Suggestions 

Proponents 

Assessment 

329 

of 

vaccines 

and  medicinal  products: 
Registration 
simplification  of  the  registration  regimes  for  vaccines  and 
medicinal products, e.g. by having any medicines or vaccines that 
are registered in a Member State automatically recognised by all 
Member  States  (Regulation  EU  2019/6,  Veterinary  medicinal 
products/VMPs). 

330 

Cost of certification: reduction in the costs of certification (e.g. 
of genetic material) and by reconsidering what should be done by 
an official veterinarian and what can be done by another official 
(Delegated Regulation (EU) 2020/686). 

331 

Definitions of cattle/bovines: request to define the term ‘cattle/ 
bovines living under semi-wild conditions’ and set a derogation 
for the identification of these animals (Regulation (EU) 2016/429 
(‘Animal Health Law’)). 

The  objective  of  this  proposal  is  already  addressed  by  Regulation 
2009/6 on Veterinary Medicinal Products (VMPs). It already provides 
for  the ‘centralised  procedure’  (Articles.  42  to  45),  under  which the 
marketing authorisations of VMPs are granted by the Commission and 
valid across the EU i.e. in all Member States). The ‘decentralised’ and 
‘mutual  recognition’  procedures  (Articles.  42  and  52,  respectively) 
also provide for the authorisation of a VMP in several Member States. 
The ‘subsequent recognition’ procedure (Article 53) provides for the 
authorisation  of  aa  VMP  by  additional  Member  States.    Further 
provisions  (Articles.  112  to  116)  allow  the  use,  under  certain 
circumstances, of VMPs authorised in other Member States. 

The  type  of  information  and  attestation  that  must  be  certified  by 
officials necessitate a person with a veterinary degree (e.g. to certify 
the presence or absence of clinical signs, tests related to transmissible 
animal  diseases,  official  controls  related  to  the  activities  of  the 
veterinarian who is responsible for collecting and producing germinal 
products and running the germinal products establishment, etc.). This 
is also in line with international standards. 

The  proposal  has  not  been  taken  up  as  it  is  legally  not  possible. 
Regulation (EU) 2016/429 defines in Article 4 animals as either kept 
(i.e. kept by humans), or wild (not kept by humans). This regulation 
leaves it up to the competent authority in each Member State to decide, 
depending on the specific circumstances, whether animals should be 
considered as kept or as wild. This may depend on several factors, and 
it is often a case-by-case decision taking into account the risk those 
animals  pose  for  animal  and  public  health.    Moreover,  several 
derogations  for  animals  kept  in  extensive  conditions  are  already 
provided in Commission Implementing Regulation (EU) 2021/520 as  
regards identification and registration. Adding a new definition for a  

MT 

NL 

LV 

126 

 
 
 
Suggestions 

Proponents 

Assessment 

332 

333 

Report  on  the  transfer  of  sheep  and  goats  from  farms  to 
grazing  areas  (amendment  of  Commission  Implementing 
Regulation  (EU)  2021/520  on  traceability  of  certain  kept 
terrestrial animals). 

Differentiated  health  standards:  request  for  differentiated 
health  standards  depending  on  the  destination  of  the  animal 
product:  export,  national  and/or  short  circuit;  simplified  health 
standards for mixed crop and livestock farms and allowing open-
air breeding. 

AT 

COPA-
COGECA 

ECVC 

category of semi-wild animals would not, however increase the clarity 
of  the  rules,  but even  reduce  their  clarity.  It  would also  undermine, 
animal traceability, a key element in  disease  prevention and  control 
leaving major populations of e.g. cattle, susceptible to several serious 
animal  diseases  including  zoonoses  (FMD,  LSD,  brucellosis,  etc), 
outside the effective control of the competent authorities. This would 
therefore pose a direct threat to the health of animals and to human 
health. 
In accordance with Article 3 of Commission Implementing Regulation 
2021/520, the competent authority may extend the deadline to transmit 
the  information  on  those  movements  for  bovine  animals  within  the 
same Member State from establishments of origin to registered pasture 
establishments  located  in  mountain  areas  for  grazing.  A  similar 
derogation could be laid down for ovine and caprine animals. 

Health standards and risk mitigation measures, including biosecurity, 
are  based  on  science  (risk  assessment)  and  aligned  with  SPS 
international standards regardless of the size or commercial vocation 
of farm. 

Biotechnology and novel food 

Revision  of  the  novel  food  legislation:  the  legislation  has 
become  too  restrictive,  while  the  approval  process  is  too 
expensive and time-consuming, hampering innovation.  

• Reintroduce the ‘substantial equivalence’ procedure to ease the 
burden on companies developing new food or food ingredients 
similar to already known ingredients, which do not pose safety 
risks for consumers. 

334 

DK 

• Move the cut-off date to prove that a food or food ingredient 
has been consumed to a significant degree 10 years forward.  
A  triviality  limit  for  safe  plants  used  in  small  quantities.  For 
example,  the  use  of  edible  flowers  in  restaurants  to  decorate  a 

127 

There is currently no intention to reopen the Novel Food Regulation, 
which  has  only  been  applicable  since  2018  and  has  proven  to  be 
successful in authorising innovative products when compared to the 
previous legislation on the matter.  

The  ‘substantial  equivalence’  concept  was  used  under  the  previous 
Novel Food Regulation to speed up the authorisation process at a time 
when novel food authorisations were applicant-specific. In the current 
Novel Food Regulation authorisations are generic (i.e. not related to 
specific companies), which in most cases allow for any food business 
operator to place their novel food on the market, provided the food is 

 
 
 
 
 
 
Suggestions 

Proponents 

Assessment 

dish.  Denmark  has  a  list  of  plants  that  include  various  wild 
Danish plants that are assessed to be safe. Despite this, some of 
these  plants  are  prohibited  from  use  as  there  is  no  historic 
documentation of consumption prior to 15 May 1997.  

335 

Adaptation of legislation: there is an urgent need to adapt the 
legislation  on  microorganisms  developed  with  the  help  of  new 
genomic  techniques  (NGT)  to  ensure  competitiveness  and 
contribute  to  innovation  and  sustainability,  including  the 
objectives  of  the  European  Green  Deal  and  its  Farm  to  Fork 
strategy.     

Live  NGT  microorganisms  used  e.g.  as  starter  cultures  for 
fermented foods, food supplements, probiotics for human health, 
feed additives,  and silage agents  fall  under the risk  assessment 
and  labelling  requirements  of  Regulation  (EC)  1829/2003  on 
genetically  modified  food  and  feed.  Their  use  as  biopesticides 
is  regulated  by  Directive 
and  biofertilisers  (inoculants) 
2001/18/EC  on  the  deliberate  release  of  GMOs  into  the 
environment.  These  legal  acts  need  to  be  adapted  to  allow  the 
development and marketing of NGT microorganisms in the EU, 
while maintaining a high level of safety for human and animal 
health and for the environment.  

DK 

128 

compliant with the authorised specifications and conditions of use, in 
other words essentially equivalent to an already authorised novel food. 

The safety assessment of novel foods is conducted by EFSA. EFSA is 
about to adopt a guidance document on the safety assessment of novel 
foods:  Member  State  authorities  have  had  the  possibility  to  express 
their views on what should be changed and how. 

By keeping the date of 15 May 1997, the Parliament and the Council 
aimed to provide legal certainty, predictability and equal treatment in 
all situations and for all food business operators submitting novel food 
applications, thus providing for regulatory consistency. 

Any potential new policy initiative addressing NGT microorganisms 
first of all needs a solid scientific basis. 

The  Commission  has  started  to  lay  this  foundation,  by  mandating 
specific work to EFSA and the European Union Reference Laboratory 
together with the European Network of GMO Laboratories.  

In  addition,  in  the  context  of  the  Commission’s  Communication  on 
’Building  the  future  with  nature:  boosting  biotechnology  and 
biomanufacturing in the EU’ (COM(2024) 137 final), the Commission 
will  launch  a  study  analysing  how  the  legislation  that  applies  to 
biotechnology  and  biomanufacturing  could  be  further  streamlined 
across EU policies, exploring targeted simplifications to the regulatory 
framework,  including  for  faster  approval  and  bringing  products  to 
market  more  quickly.  The  study  will  be  finalised  by  mid-2025  and 
could lay the foundations for a possible EU Biotech Act. 

 
 
Annex 3. Impact analysis: who is affected and how? 

This staff working document mostly makes use of a qualitative assessment of measures taken 
to address the issues brought to light during farmers’ protests. The Commission has proposed 
to change certain provisions of the CAP.  

These proposals will mainly reduce the burden related to checks on EU farmers. They will also 
provide them with greater flexibility in complying with certain environmental conditionalities, 
without undermining the related policy objectives. National administrations will also benefit 
from greater flexibility in applying certain standards.  

It is difficult to estimate the time spent on checks, but rough assumptions have been made to 
provide an indication of the effect of the elements of the simplification package. These were 
also based on the replies received to the questionnaire ‘Simplifications - the farmers’ point of 
view’ through the EU survey platform.  

The  measures  quantified,  including  those  referring  to  reporting  under  CAP  rules  and  to  the 
Area Monitoring System (AMS), will bring estimated savings of around EUR 164 million per 
year for farmers and administrations together. This refers mainly to administrative savings and 
does not include other impactful initiatives, such as those on biodiversity, crop rotation or soil 
coverage.  

Revision of the EU methodology for the quality assessment of the AMS  

The  Commission  has  adjusted  the  methodology  of  the  AMS,  so  that  Member  States  can 
significantly reduce the number of visits to farms, while maintaining the effectiveness of the 
methodology  to  ensure  that  taxpayers  funds  are  well  spent.  In  particular,  the AMS  quality 
assessment provides diagnostic information on the sources of incorrect decisions at the level 
of interventions and eligibility conditions, with the aim of improving the Member States’ AMS. 
This will result in a reduction of at least 50% in the number of visits to holdings and a reduction 
of on-the-spot checks for AMS quality control of up to 3% for all holdings, which translates to 
174 000  fewer  controls.  Using  the  standard  cost  model,  and  assuming  an  average  12  hours 
dedicated by a farmer to a single visit this equals a reduction of total cost for farmers of EUR 
61.8 million, linked to time spent on these on-the-spot controls, and of EUR 82.4 million for 
national  administrations  in  the  Member  States  assuming  a  workload  of  2  working  days  per 
control. 

Exemption of small farms (under 10 ha) from conditionality controls 

The  Commission  proposed  to  exempt small  farms  of  under  10  hectares  from  controls  and 
penalties related to compliance with conditionality requirements. This will significantly reduce 
the administrative burden related to  controls for  small  farmers,  who represent  65% of CAP 
beneficiaries, and will result in approximately 37 600 fewer controls every year. We estimate, 
using the standard cost model that this will produce savings of around EUR 6.7 million for 
farmers assuming a simple metric of 0,75 working day per control for a farm below 10 hectares 
(6 hours, drawing on the results of the recent survey of farmers).  Assuming a workload of 1,5 
day per control for administrations this translates into EUR 13.4 million of savings for national 
administrations, based on average EU values for labour costs (in hourly earnings) using the 
standard cost model. 

129 

 
 
 
Use of the force majeure and exceptional circumstances clause 

The  application  of  the  concept  of  force  majeure/exceptional  circumstances  will  reduce  the 
administrative burden for farmers by eliminating the need to introduce individual requests and 
for a case-by-case assessment by national administrations. It was not possible to quantify the 
benefits as this depends on the occurrence of unpredictable events. 

Rationalisation of controls including the right of error/exemption of farmers subject to 
conditionality from cross-compliance controls 

This will result in fewer on-site visits from the national administration and will benefit farmers 
by leaving them more time to work. Rationalisation will also reduce uncertainty since it will 
prevent the withdrawal  of CAP support and will positively impact the mental well-being of 
beneficiaries. It will ease the control burden, remove the hassle costs for these beneficiaries 
and will result in cost benefits for national administrations, though these benefits could not be 
quantified due to the lack of data.  

Adjustments to GAECs 

Changes to the rules under the GAECs will give Member States the possibility to allow farmers 
to better manage their farms in response to market developments and weather conditions, thus 
supporting their economic viability. Farmers will be able to better organise soil preparation and 
the related financial risks will be reduced. The flexibility and the removal of certain restrictions 
on  farm  management  are  intended  to  simplify  farmers’  daily  work,  address  any 
incomprehension or frustration linked to what farmers perceive as the unnecessary interference 
of policymaking in farm management, and address their income related concerns.  

Lifting  the  GAEC  8  first  requirement  is  estimated  to  impact  roughly  1.1  million  farms  by 
freeing  close  to  2.1  million  hectares  of  GAEC  8  non-productive  land  for  production.  The 
economic impact measured as the annual change in the gross margin of arable crops (additional 
income/avoided income loss), is estimated to be around EUR 930 million. This corresponds to 
a 1.5% increase in gross margin for the impacted farms. 

These adjustments  require modifications of  certain  PMEF  elements    of the CAP plans. The 
incorporation  of  new  eco-schemes  in  the  CAP  Plans  may  require  the  reallocation  of  the 
financial allocations. These changes may incur adjustment costs for national administrations 
(it has not been possible, however, to quantify this increase). 

Table 1 provides a qualitative overview of the key benefits of the measures in the simplification 
package. Table 2 presents an estimation of cost savings and Table 3 describes how the one in, 
one out approach will be applied. 

130 

 
 
 
 
Summary of costs and benefits 

Table 1 - Overview of benefits  

I. Overview of benefits (total for all provisions) – preferred option 

Description 

Amount 

Comments 

Direct benefits 

Benefits for farmers – 
reduction in administrative 
costs 

EUR 61.8 million 
annually 

Revision of the IACS quality system will result in fewer visits to farms.  

EUR 6.7 million 
annually 

Exemption of small farms (under 10 ha) from conditionality controls will 
result in fewer controls* 

The Commission’s clarification of the concept of force 
majeure/exceptional circumstances reduces the administrative burden for 
farmers as it eliminates the need to introduce individual requests, 
including gathering the evidence and providing it to the authorities. 

Exemption of farmers subject to conditionality from cross compliance 
controls will contribute to the simplification of controls. 

Not quantifiable 

Benefits for farmers - 
reduced uncertainty and 
hassle costs 

Not quantifiable  Reduction of uncertainty for farmers with the improvements to the early 

warning systems and the right of error. 
Reduction of uncertainty costs resulting in positive impacts on farmers’ 
frustration due to adjustments to rules under the GAECs.  

Benefits for farmers – 
improved economic 
viability of farms 

EUR 930 million 
annually 

Deletion of GAEC 8, 1st requirement, is estimated to result in a 1,5 % 
increase in gross margin for the impacted farms. 
Additional benefits (not quantifiable) include better management of 
farms, support of economic viability and preservation of land 
productivity thanks to adjustments to rules under GAECs* 

Benefits for national 
administrations – reduction 
in enforcement costs 

EUR 82.4 million 
annually 

The revision of the IACS quality assessment methodology will result in 
cost savings for national administrations. 

EUR 13.4 million 
annually 

The removal of controls on conditionality for farms under 10 hectares 
will result in cost savings for national administrations* 

Not quantifiable 

The clarification of the concept of force majeure eliminates the need for 
a case-by-case assessment by national administrations. 

Exemption of farmers subject to conditionality from cross compliance 
controls will contribute to the simplification of controls. 

Not quantifiable 

Rationalising controls, including the right of error, will reduce 
administrative checks by national administrations. 

Streamlined process to approve CSP amendments will reduce 
administrative costs.  

Indirect benefits 

Benefits for farmers - 
positive impact on mental 
well-being  

Not quantifiable  Reduction of uncertainty and hassle with a positive impact on farmers’ 

well-being by reducing stress factors. 

* Actions embedded in Regulation (EU) 2024/1468 (The Simplification Regulation). 

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2 - Overview of costs  

II. Overview of costs  

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct 
administrative 
costs 

Direct 
enforcement costs 

Direct 
administrative 
costs 

Direct 
enforcement costs 

Direct 
administrative 
costs 

Direct 
enforcement costs 

Direct 
administrative 
costs 

Direct 
enforcement costs 

Direct 
administrative 
costs 

Direct 
enforcement costs 

Direct 
administrative 
costs 

Commission’
s clarification 
of the 
concept of 
force 
majeure 

Revision of 
the IACS 
quality 
system will 
result in a 
reduced 
number of 
visited farms  

Removal of 
controls on 
conditionalit
y for farms 
under 10 
hectares* 

Exemption of 
farmers 
subject to 
conditionalit
y from cross 
compliance 
controls 

Rationalising 
controls, 
including the 
right of error 

Streamlined 
approval 
process of 
CSP 
amendments 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Lifting of 
GAEC 8, 1st 
requirement* 

Indirect cost -  
GHG reduction 
not materialised  

0 

Not monetised; 
estimated at 
900 kt CO₂ eq 

132 

0 

- 

0 

- 

0 

- 

0 

- 

0 

- 

- 

- 

Reduction in 
costs (not 
quantifiable) 

- 

- 

0 

- 

Reduction in 
costs (not 
quantifiable) 

- EUR 61.8 
million 

- 

- 

- 

0 

- EUR 82.4 
million 

- EUR 6.7 
million 

- 

- 

0 

Reduction in 
costs (not 
quantifiable) 

- 

Reduction in 
costs (not 
quantifiable) 

- 

0 

- 

0 

- 

- 

        0 

- 

- EUR 13.4 
million 

- 

Reduction in 
costs (not 
quantifiable) 

- 

Reduction in 
costs (not 
quantifiable) 

Reduction in 
costs (not 
quantifiable) 

- 

- 

- 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Adjustment costs 
- reallocation of 
financial 
allocations, 
incorporation of 
new eco-schemes, 
modification of 
result indicators 

Adjustments 
to certain 
GAECs 

TOTAL 

- 

- 

- 

- 

Increase in 
costs (not 
quantifiable) 

0 

n/a 

n/a 

n/a 

- EUR 68.5  
million 

- EUR 95.8 
million 

n/a 

* Actions embedded in Regulation (EU) 2024/1468 (The Simplification Regulation). 

Table 3 – One in, one out  

III. Application of the ‘one in, one out’ approach 
(EUR million) 
Farmers 
Removed administrative 
burdens (OUTs) 

One-off 

0 

Recurrent 

Total 

EUR 68.5 million 

EUR 68.5 million 

133 

 
 
 
 
 
 
 
Annex 4. Modelling the impact of the removal of the GAEC 8 first requirement (share of 
non-productive areas and elements in arable land) according to the IFM-CAP model.  

The Individual Farm Model for Common Agricultural Policy Analysis (IFM-CAP) is a model 
designed  by  the  Commission’s  Joint  Research  Centre  for  the  ex-ante  economic  and 
environmental assessment  of the medium-term  adaptation  of individual farms to  policy and 
market changes. The IFM-CAP simulates how a given scenario, for example a change in farm 
resources, or environmental or agricultural policy (in the specific case, a change in GAEC 8 
requirements), might affect a set of selected indicators.  

To  obtain  the  estimate  of  the  economic  impact  of  the  removal  of  the  GAEC  8  first 
requirement,  the  IFM-CAP  has  been  applied  to  each  individual  farm  recorded  in  the  Farm 
Accountancy Data Network (FADN)73. This database of the income and business activity of 
roughly  80  000  EU  commercial  farms  has  been  used  to  ensure  the  highest  possible 
representativeness  of  the  EU  agricultural  sector.  Farmers  are  assumed  to  maximise  their 
expected  utility  at  given  yields,  product  prices  and  CAP  subsidies,  subject  to  resource 
endowments and policy constraints. 

In addition to the intrinsic characteristics of the IFM-CAP model, estimating the impacts of 
removing the first requirement under GAEC 8 required additional assumptions, as explained 
below.  

The economic impact of the policy change is estimated as the income of the land potentially 
‘freed up’ by the lifting of the GAEC 8 first requirement for farms that would be subject to this 
requirement. More precisely, for the impacted farms it is measured as the change in income 
that  results  from  the  product  of:  (i)  the  area  of  land  lying  fallow  due  to  the  GAEC  8  first 
requirement; and (ii) the gross margin of the arable crop that would be cultivated in this ‘GAEC 
8 fallow area’.  

1.  The first step (i) consists in estimating the area of fallow land that is fallow due to 
the GAEC 8 first requirement. This is done, for each farm in the FADN database, as 
follows: 
(a)  Multiplying  the  arable  land  area  recorded  in  FADN  by  4%  as  mandated  by  the 
GAEC 8 first requirement.  For the 15 Member States where farms had been given 
the option to comply with the requirement of GAEC 8 by leaving 3% of arable land 
as fallow (instead of 4%), combined with an extra 4% of area covered with catch 
crops  or  nitrogen-fixing  crops  cultivated  without  the  use  of  plant  protection 
products, it is assumed that all farms would adopt this option74. This assumption is 
made, in the absence of precise, farm-level data on the uptake of this option at the 
time of writing. 

(b) Further  refining  the  estimation:  as  not  all  land  is  fallow  due  to  GAEC  8 
requirements,  land  lying  fallow  for  agronomic  reasons  i.e.  not  due  to  policy 
requirements, but as a business-driven decision of the holding (‘voluntary fallow’), 
is estimated and subtracted from the previous calculation. This estimation is based 
on the share of fallow land in farms not subject to EFA requirement in the pre-2023 

73 https://agriculture.ec.europa.eu/data-and-analysis/farm-structures-and-economics/fadn_en. For the estimations 

FADN 2020 data are the basis. 

74 BE, BG, CZ, EE, EL, ES, NL, PT, FR, CY, LT, HU, PL, RO, SK as in approved-28-cap-strategic-plans-2023-

27.pdf (europa.eu) p 55. 

134 

 
 
 
period. The result is an estimation of the land lying fallow due to requirements of 
GAEC 8 (‘imposed fallow’).  

(c)  In the same line of reasoning, the area devoted to landscape elements is subtracted75, 

using the amount of EFA landscape features under the pre-2023 period. 

A second step (ii) in the computation is the estimation of the gross margin of the crop that is 
assumed to be planted on the ‘freed up’ land. This is estimated by multiplying the price of 
this crop times its yield, taking into account CAP coupled payments, and subtracting the input 
costs  per  hectare  available  in  the  FADN  dataset  e.g.  seed,  plant  protection  products  and 
fertilisers.  

2.  To avoid a strong assumption of the crop assignment on the ‘freed up’ land, the assigned 
crop  is  estimated  to  be  the  one  with  the  minimum  gross  margin  among  the  ones 
already present on the holding. This is because farmers are likely to have allocated their 
least productive land as fallow land under GAEC 8. 

3.  Then, we filter in  those  farms that are actually  impacted by the change in  policy. 
Farms displaying characteristics that exempt them from the GAEC 8 first requirement76 
are excluded as there is no potential impact on income for them. Overall, about 56% of 
farms are exempted from the GAEC 8 first requirement.  

For  the  non-exempted  farms  (44%):  when  the  sum  of  the  fallow  land  and  any  landscape 
elements is equal or greater than 4% (or 3% in case of the 15 Member States) of the arable 
land, a zero impact on income from removing the GAEC 8 first requirement is assumed. This 
is because these farms already comply with the GAEC 8 requirements without having to change 
their agronomic practices. As a result of these refinements, we estimated that the removal of 
the GAEC 8 first requirement impacts roughly 1.1 million farms, covering approximately 76 
million hectares of arable land in total. Overall, the removal of the GAEC 8 first requirement  
‘frees’  an  area  of  approximately  2.1  million  hectares  that  in  the  absence  of  the  policy 
adjustment, would be required to stay non-productive. 

Implementing steps 1 to 3 for the EU-level aggregate leads to an estimated annual change of 
about  EUR  930  million  in  the  gross  margin  of  arable  crops  (the  economic  impact).  This 
corresponds to a 1.5% increase in gross margin for the impacted farms. 

The  same  modelling  framework  was  used  to  estimate  the  environmental  impact  of  the 
removal of the GAEC 8 first requirement. 

1.  In the estimation, greenhouse gas emissions are indirectly approximated by changes 
(increases) in fertiliser use due to the crops cultivated in the GAEC 8 fallow land being 
‘freed up’, as estimated above. 

75 Estimations are based on the following publication: D`Andrimont, R., Skoien, J., Koble, R., Yordanov, M. and 
Terres,  J.,  EU  Landscape  Feature  indicator  fact  sheet,  European  Commission,  2023,  JRC136069. 
https://publications.jrc.ec.europa.eu/repository/handle/JRC136069  as  well  as  Ecological  Focus  Area 
declarations under the previous programming period of the CAP. 

76 Farms with less than 10 hectares of arable land, farms where 75% of the arable land is used to produce grasses 
or other herbaceous forage, land lying fallow, cultivation of leguminous crops, or a combination of these, farms 
where more than 75 % of the eligible agricultural area is permanent grassland. 

135 

 
 
 
 
2.  To estimate the potential changes in fertiliser use, the quantity of nitrogen in mineral 
fertilisers used, as recorded in FADN, is utilised. Applying the input allocation method 
of IFM-CAP, the quantity of nitrogen in fertiliser on each crop at farm level is derived. 

3.  Once the increase in fertiliser use is estimated, the related change in  greenhouse gas 
emissions at the farm due to the application of extra fertiliser in GAEC 8 fallow land is 
calculated,  using  the  default  emission  factor  suggested  by  the  United  Nations´ 
Intergovernmental Panel on Climate Change (2019)77. 

Other  environmental  impacts,  notably  on  biodiversity,  could  not  be  quantitatively  assessed 
using the IFM-CAP at the time of writing. 

77 https://www.ipcc-nggip.iges.or.jp/public/2019rf/pdf/4_Volume4/19R_V4_Ch11_Soils_N2O_CO2.pdf  

136