COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2021/2115 as regards the conditionality system, types of intervention in the form of direct payment, types of intervention in certain sectors and rural development and annual performance reports and Regulation (EU) 2021/2116 as regards data and interoperability governance, suspensions of payments annual performance clearance and controls and penalties
Date: 2025-05-14
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: EAFRD, EAGF, EU financing arrangements, activity report, administrative formalities, aid to agriculture, rural development, sanction (EU), single payment scheme, suspension of payments, sustainable agriculture

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.5.2025  SWD(2025) 236 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2021/2115 as regards the conditionality system, types of intervention in the form of direct payment, types of intervention in certain sectors and rural development and annual performance reports and Regulation (EU) 2021/2116 as regards data and interoperability governance, suspensions of payments annual performance clearance and controls and penalties {COM(2025) 236 final}  
 
 
CONTENTS 

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

2.  CONSULTATION STRATEGY AND EVIDENCE GATHERING ................................ 3 

2.1  Consultation strategy .......................................................................................................... 3 

2.2. Further evidence ................................................................................................................. 7 

3.  DESCRIPTION OF THE MEASURES AND THEIR IMPACTS .................................. 9 

3.1  On-farm  simplification  and  streamlining  of  requirements  to  better  recognise  various 
situations and farming practices ......................................................................................... 9 

3.2. Streamlining support for smaller and medium-sized farms ............................................. 17 

3.3. Measures to boost competitiveness .................................................................................. 18 

3.4. Greater flexibility to Member States in the management of CAP Plans .......................... 23 

4.  CONCLUSIONS AND NEXT STEPS ............................................................................. 27 

ANNEX  –  Table  of  estimated  savings  for  farmers  and  national  administrations  for 
quantifiable measures in the 27 Member States .......................................................... 28 

1 

 
 
 
 
 
 
Glossary  

Term or acronym 

Meaning or definition 

AECC 

Agri-environment-climate commitments 

AGRIFISH Council 

Agriculture and Fisheries Council configuration 

AMS 

APR 

BISS 

BPR 

CAP 

Area Monitoring System 

Annual performance report 

Basic income support for sustainability 

Biennial performance review 

Common agricultural policy 

CAP Plan  

CAP strategic plan 

CSP Regulation 

CAP Strategic Plan Regulation (Regulation (EU) 2021/2115) 

EAGF 

EAFRD 

GAEC 

GSA 

Horizontal 
Regulation  

IACS 

LPIS 

LU 

SCO 

European Agricultural Guarantee Fund 

European Agricultural Fund for Rural Development 

Good agricultural and environmental condition standard 

Geo-spatial application 

Regulation on the financing, management and monitoring of the common 
agricultural policy (Regulation (EU) 2021/2116) 

Integrated administration and control system 

Land parcel identification system 

Livestock unit 

Simplified cost options 

2024 simplification 
package 

2024 Simplification 
Regulation  

The package of measures put forward by the Commission on 22 February 2024, 
including the Commission proposal of 15 March 2024 to amend the CSP Regulation 
and the Horizontal Regulation (Regulation (EU) 2024/1468)  

Regulation (EU) 2024/1468 of the European Parliament and of the Council 
amending the CSP Regulation and the Horizontal Regulation based on the 
Commission proposal of 15 March 2024 

Simplification study 

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

SMR 

ULM 

Vision 

Statutory management requirement 

Union-level methodology 

Commission Communication ‘A Vision for Agriculture and Food’ 

2 

 
 
1.  INTRODUCTION 

On 19 February 2025, the European Commission  adopted the Commission Communication  
‘A Vision for Agriculture and Food’1. This Communication presents a roadmap to guide EU 
action towards achieving an attractive, competitive, resilient, future-oriented and fair agri-food 
system for current and future generations of farmers and agri-food operators.  

In line with the EU Competitiveness Compass, the overarching EU flagship initiative to boost 
EU  competitiveness2  and  following  the  Draghi  report3,  the  Vision  calls  for  unnecessary 
bureaucratic and regulatory burden to be reduced, a key step to support the competitiveness of 
the farming sector and the entire agri-food value chain.     

As a first step in that process, the Vision announced a comprehensive simplification package 
of the current agricultural legislative framework (2023-2027) to deliver in the following 
areas: (i) on-farm simplification and streamlining of requirements to better adjust to different 
situations and to various farming practices; (ii) streamlining support for smaller and medium-
sized farms; (iii) providing measures that can help boost competitiveness; and (iv) increasing 
Member States’ flexibility in managing CAP strategic plans (CAP Plans).  

This staff working document accompanies the Commission simplification proposal amending 
the CAP Strategic Plan (CSP) and the Horizontal Regulations4. It includes (i) a summary of the 
key input and feedback from stakeholders and other evidence that informed this initiative, (ii) 
an explanation of the solutions found to address the identified problems together with (iii) an 
assessment of their impacts, particularly the expected reduction of administrative burden for 
farmers and national administrations.  

2. 

CONSULTATION STRATEGY AND EVIDENCE GATHERING 

The  Commission  developed  the  legislative  proposal  based  on  the  evidence  available 
concerning the implementation of the CAP Plans in 2023 and 2024, including feedback from 
the European Parliament’s Committee on Agriculture and Rural  Development, the Council, 
Member States, farmers’ organisations and other civil society groups. It relied on information 
from regular or dedicated exchanges in expert groups, the Civil Dialogue Group on the CAP 
Strategic Plans and Horizontal Matters, the CAP Network, ad hoc contributions and various 
analytical activities, such as data, studies and internal analyses.  

2.1 .  Consultation strategy 

In preparing this proposal, the Commission reviewed input from  national administrations, 
the  European  Parliament’s  Committee  on  Agriculture  and  Rural  Development,  and 
farmers' representatives that was provided in the context of the 2024 simplification.  

1   Commission Communication ‘A Vision for Agriculture and Food Shaping together an attractive farming 

and agri-food sector for future generations’, COM (2025) 75 final 

2   European Commission (2025), A Competitiveness Compass for the EU, COM(2025) 30 final. 
3   Draghi, M., The future of European competitiveness, September 2024. 
4   Regulation (EU) 2021/2115, Regulation (EU) 2021/2116, respectively 

3 

 
 
 
This included over 500 individual suggestions covering issues related to: 

•  management of CAP Plans and procedures around (i) amending the Plans (including 
the  number  of  allowed  amendments),  (ii)  performance  monitoring  and  review 
(including  the  Annual  Performance  Report),  (iii)  certain  elements  of  the  Integrated 
Administration  and  Control  System  (simplification  of  the  Area  Monitoring  System, 
quality  assessment  methodology,  the  use  of  geo-tagged  photos,  and  geo-spatial 
applications) as well as (iv) the control and penalty system (including rationalisation of 
all controls on a farm);   

•  actions under the CAP Plans that benefit the environment and the climate: changes 
to conditionality requirements and controls, and other related issues such as treatment 
of small farms or financial management of environmental interventions;   

•  other CAP provisions beyond environment and climate, such as expanding coupled 
income support, postponing or removing social conditionality, or changes to sectoral 
support  schemes,  promotion  measures  and  organic  farming.  There  were  also 
suggestions calling for a more fundamental rethink of EU agricultural policy;   

• 

issues  relating  to  farm  income,  particularly  to  risk  and  crisis  management,  with 
suggestions to: (i) allocate more CAP funds to crisis management; (ii) revise CAP rules 
on support to risk management instruments; and (iii) take action to improve the farmers’ 
position in the food chain;   

• 

legislation outside the CAP, such as that on deforestation, forest monitoring, sanitary 
rules, or renewable energy.   

Some of these suggestions were addressed fully or partially in the 2024 simplification package 
of  legislative  and  non-legislative  measures  (e.g.  flexibilities/temporary  derogations  for 
GAECs, exempting farmers with an agricultural area below 10ha from controls and penalties, 
or adjustments to quality assessment of Area Monitoring System components reducing the need 
for on-site visits) 5. An assessment of all these suggestions was included in the staff working 
document of December 20246. 

The simplification debate continued in 2024 and 2025, with specific calls from Member States 
to address the difficulties with the annual performance clearance procedure. The issue featured 
highly in the debate at the AGRIFISH Council of 27 January 20257, where all delegations 
welcomed the Commission’s initiative towards further simplification, especially in relation to 
annual performance clearance. However, they also stressed the need to go further, increasing 
flexibility of the CAP framework overall or in relation to its specific elements.  

Following  the  debate,  Member  States  submitted  over  400  individual  suggestions.  The 
majority  concerned  the  CAP  with  some  calling  for  changes  outside  the  CAP  or  holding 
expectations for the next CAP programming period, often reiterating issues raised in the 2024 
submissions. These suggestions include: 

•  Management of CAP strategic plans: suggestions were made relating to (i) the length 
of  the  amendment  procedure,  with  a  call  for  extending  the  notification  procedure  to 

5   Regulation (EU) 2024/1468 (2024 Simplification Regulation) 
6   SWD (2024) 360 final 
7   https://www.consilium.europa.eu/en/meetings/agrifish/2025/01/27/  

4 

 
 
 
other amendments; and (ii) the need to revise or discontinue the annual performance 
clearance  procedure,  and  to  modify  annual  performance  reports  and  the  biennial 
performance review.  

•  Environmental and climate (green) architecture: many suggestions called for greater 
flexibility  as  regards  conditionality,  including  (i)  a  withdrawing  or  postponing  the 
implementation of GAEC 2 on wetlands and peatlands considering organic farmers are 
compliant with some GAEC requirements; (ii) replacing some GAECs with voluntary 
interventions; and iii) simplifying the related control and penalty systems. There were 
also some requests made regarding support rates under eco-schemes and the flexibility 
of  their  financial  management,  and  the  length  of  commitments  under  the  agri-
environment-climate  interventions  as  well  as  the  possibility  of  incorporating  an 
incentive element into these interventions when designing the level of support. 

•  Financing (rules) of the CAP: there were suggestions for greater flexibility as regards 
(i) the use of financial envelopes or the way modifications are made in various payments 
(coupled 
farmers);  
income  support,  payments 
(ii) decommitment rules; and (iii) advance payments. 

for  young  and 

for  small 

•  Other  suggestions,  for  example,  using  risk  management  instruments  such  as  for 
financial  contributions  to  these  tools  or  when  calculating  compensation  for  losses; 
abandoning the implementation of social conditionality; and introducing rules related 
to the way support is provided, such as limiting the number of on farm visits. There 
were also suggestions to simplify the process of programming by reducing requirements 
when it comes to preparing programming documents. 

Simplification also featured in the Structured Dialogue of the Commissioner for Agriculture 
and  Food  with  the  European  Parliament’s  Committee  on  Agriculture  and  Rural 
Development that took  place on 8 April 2025. The forthcoming package was welcomed by 
MEPs, especially its focus on national specificities and practical implementation. However, it 
was  also  pointed  out  that  much  of  the  complexity  faced  by  farmers  stems  from  national 
implementation and Member States have a role to play in reducing red tape.  

At the inaugural meeting of the European Board on Agriculture and Food (EBAF)8 held on 
4 February 2025 and dedicated to discussing the Vision for Agriculture and Food, members 
raised the importance of simplification for the future of the policy, while also cautioning against 
deregulation and emphasising the need for smart implementation and enforcement.  

A  dedicated  meeting  of  the  Civil  Dialogue  Group  on  the  CAP  Strategic  Plans  and 
Horizontal  Matters  (CDG)9  was  convened  on  24  March  2025  to  discuss possible 
simplification  measures,  along  the  four  avenues  set  out  in  the  Vision.  The  participants 
underlined  the  need  for  streamlined  processes,  reduced  administrative  tasks,  clear 
communication,  a  transparent  and  collaborative  environment,  and  coherent  legislation  that 
empowers farmers.  

8   https://agriculture.ec.europa.eu/common-agricultural-policy/cap-overview/committees-and-expert-

groups/ebaf_en  

9   https://agriculture.ec.europa.eu/common-agricultural-policy/cap-overview/committees-and-expert-

groups/civil-dialogue-groups/cap-strategic-plans-and-horizontal-matters_en  

5 

 
 
 
The participants raised specific concerns and expectations: 

•  They  called  for  simplification  to  focus  on  maintaining  productivity,  which  would 
strengthen  of  the  CAP’s  economic  pillar  to  restore  balance  and  improve  farmer 
competitiveness in light of rising input costs. 

•  They  highlighted  problems  related  to  some  of  the  key  definitions  such  as  ‘active 
farmer’, ‘eligible hectare’ and ‘permanent grasslands’ with calls for their revision. 

•  They  highlighted  complexity  and  compliance  challenges  surrounding 

the 
implementation  of  GAECs  where 
legislation 
these 
(wetlands/peatlands and buffer strips). They also requested a more nuanced approach 
to  conditionality  for  organic  and  smaller  farms,  to  ensure  the  former  are  not  unduly 
burdened by standard requirements that may not  align with  organic methods, and to 
ensure the latter are not obligated to make a disproportionately high level of effort.  

intersect  with  national 

•  They  underscored  inconsistencies  in  eco-scheme  timelines,  as  some  are  designed 

biannually. 

•  They  made  calls  not  to  lower  the  level  of  environmental  protection  by  removing 
environmental  rules  that  protect  strategic  natural  resources  and  which  complement 
other EU legislation (Nature Restoration Law). There is an expectation that funding for 
voluntary  measures  will  be  increased  in  case  of  reduction  in  the  ambition  of 
conditionality is reduced.  

•  They highlighted difficulties with monitoring issues related to geo-tagged photos and 
potential  inaccuracies  and  called  for  changes  that  would  limit  the  frequency  and 
duration of on-farm inspections.  

•  They  underscored  challenges  linked  to  frequent  modifications  in  CAP  plans  with 

suggestions that the Commission for only approve major changes. 

•  They  requested  a  simplified  approach  to  risk  and  crisis  management,  while 
preventing  market  distortion,  including  the  use  of  calculation  rules  for  yield  losses 
under risk management instruments. 

•  While some participants saw social conditionality as a source of sanctions for farmers 
already  subject  to  the  relevant  national  legislation,  others  stressed  it  should  remain, 
underlining  its  objective  to  ensure  that  public  support  is  tied  to  and  upholds  these 
societal standards. 

•  There were suggestions in relation to support for young farmers, to facilitate farm 
transfer,  and  ensure  access  to  knowledge  so  new  entrants  can  navigate  the  CAP 
landscape effectively.  

•  Other issues were raised such as: i) a lack of accurate data on new agroforestry areas 
supported  by  the  CAP,  affecting  the  ability  to  track  progress  and  communication  to 
potential investors and farmers; ii) the need for investment in biosecurity and biosafety, 
and  iii)  tackling  complexities  around  plant  protection  rules  (without  compromising 
environment and health). 

6 

 
 
Some  of  these  issues  were  also  reflected  in  organisations’  the  written  contributions  these 
organisations  provided,  which  were  received  before10  or  during  the  follow-up  to  the  CDG 
meeting11.  

A joint statement from 60 NGOs was also received. This relayed concerns about the scope of 
simplification,  and  provided  recommendations  to  increase  funds  allocated  to  eco-schemes, 
strengthening  rather  than  weakening  GAEC  standards  and  SMR  requirements,  and  require 
Member States with significant peatlands to offer farmers voluntary measures with incentive 
components  to  boost  their  appeal.  They  also  advocated  for  better  advisory  support,  stricter 
investment  rules  to  help  sustainable  transition,  and  linking  CAP  payments  to  measurable 
outcomes.  To  reduce  administrative  burden,  they  recommended  harmonising  reporting 
processes, increasing digitalisation, and providing effective communication and clarification, 
although they acknowledged that dealing with many simplification challenges would fall under 
the responsibility of national authorities. The importance of maintaining performance reporting 
was underlined to ensure accountability and accurate monitoring of CAP funds. 

The  first  meeting  of  the  Thematic  Group  on  simplification  of  the  CAP  Network  was 
convened  on  2 April  202512.  The  participants  took  stock  of  challenges  related  to  different 
aspects of CAP implementation and exchanged views on simplification measures and practices 
that  Member  States  implement  to  handle  CAP  applications,  reporting  requirements  and 
controls, inspections and monitoring.  

Specific challenges for countries with regionalised CAP governance were discussed. A level 
playing field was recognised as an important component, with participants stressing the need 
for Member States and farmers to have equal access to broadband, support systems or advisory 
services, so they can benefit equally from the policy, which they felt was not always the case.  

The participants exchanged views on the experience of digital tools used across Member States, 
noting  they  save  time  for  administration  and  beneficiaries,  increase  transparency,  ease  the 
application and selection process, help avoid duplications. The use of simplified cost options 
(SCO) was regarded as real simplification, even if entailing significant effort at the beginning, 
and  that  should  also  be  used  for  investments.  The  Commission  needs  to  provide  greater 
assurance of its acceptability. Complexity or detailed reporting requirements can be overcome 
by implementation choices, such as SCOs. Simplified terminology can help avoid confusion. 
Some participants noted that the number of controls on farms vary considerably and could be 
limited by introducing a concept of one farm visit per year independent of funds received.  

2.2.  Further evidence  

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

Further  evidence  was  gathered  following  a  survey  about  farmers  that  in  March-April  2024 
collected  close  to  27  000  replies  on  their  experience  and  perceptions  of  applying  for  CAP 

10   Copa-Cogeca - European farmers/European agri-cooperatives 
11   The European Agroforestry Federation, the European Coordination Via CAMPENSINA, the Confederation 

of European Forest Owners and the European State Forest Association. 

12   https://eu-cap-network.ec.europa.eu/events/1st-meeting-thematic-group-effective-approaches-

simplification-within-cap_en  

7 

 
 
 
support  and  the  associated  obligations13.  Together  with  in-depth  follow-up  interviews,  and 
surveys  and  interviews  of  other  CAP  beneficiaries  and  stakeholders,  the  survey  informed  a 
study on simplification for farmers and other beneficiaries14.  

The study highlights the perceptions of various challenges related to CAP (and some other non-
CAP) obligations, whether stemming from EU and/or national level choices (note that much 
of the input was collected before the 2024 simplification package entered into effect), which 
include the following: 

•  unclear or frequently changing rules, delays in communication and multiple legislative 
layers  that  prevent  people  from  fully  understanding  the  applicable  provisions  when 
preparing applications for CAP support. Difficulties with the application process 
include excessive evidence collection, issues with digital tools (mainly for identifying 
eligible areas for area-based interventions), and follow-up procedures (often linked with 
the  Area  Monitoring  System  (AMS)  and  the  requests  for  geo-tagged  photos). 
Investment applications are seen as especially challenging because of the extensive 
documentation required, including cost justifications;  

•  burdens related to recording and reporting, including the repeated submission of the 
same information to the same or different authorities, and issues related to digitalisation 
(e.g. manual recording or misalignment between recording and reporting systems);  

income/profit  frameworks 

in  which  farmers  operate  versus 

•  difficulties complying with conditionality and other environmental requirements, 
with challenges due to timeline or territorial misalignment with farming realities, short-
term 
long-term 
improvements  promoted  by  these  rules.  These  result  in  distrust  and  a  perception  of 
compliance  being  burdensome  rather  than  beneficial.  Other  issues  relate  to  overlaps 
with national legislation or unclear definitions (e.g. buffer strips or non-productive 
areas). Respondents found the requirements that they understood or are familiar with 
and that aligned with standard farming practices to be less complex. To be noted that 
the  data  collection  of  the  study  on  simplification  was  carried  before  the  2024  CAP 
simplification package entered in force and several elements identified by farmers were 
already addressed by it; 

•  controls and inspections (linked to different purposes, including CAP aid, non-CAP 
and  national  legislation):  redundancy,  which  is  exacerbated  by  the  time-consuming 
nature  of  preparing  and  attending  inspections,  unclear  rules  underpinning  controls, 
inflexibility 
in  rule  enforcement  (e.g.  sanctions  for  minor  violations)  and 
communication  with  inspectors,  whose  behaviour  and  perceived  competence  can 
positively or negatively influence farmers’ experience with controls. 

Administrative burden corresponds to the cost of collecting and processing information and 
the study sought to identify and quantify these costs through targeted consultation with farmers 
and  thematic  surveys. Although  there  is  an  expected  variance  in  costs  experienced  across 

13   https://agriculture.ec.europa.eu/consultations-eu-initiatives-agriculture-and-rural-development/farmers-

consultation-simplification_en 

14    European Commission – Directorate-General for Agriculture and Rural Development – Unit A.3 (2025): 
Study on simplification and administrative burden for farmers and other beneficiaries under the CAP, 
available at: https://eu-cap-network.ec.europa.eu/publications/study-simplification-and-administrative-
burden-farmers-and-other-beneficiaries-under    

8 

 
 
 
Member States and among farmers, influenced by the size of their farms, farm types and types 
of aid application, it was estimated that farmers face an average annual cost of EUR 1 230 
as a result of the estimated time spent on CAP-related administrative tasks. Approximately 
half  of  these  costs  are  attributable  to  internal  costs  such  as  administrative  tasks  and  the 
remainder attributable to external advisory services.  

The  solutions  proposed  by  the  participants  would  aim  to  tackle  the  overall  design  of 
legislation,  advocating  for  clearer,  simpler,  and  more  stable  rules,  along  with  flexibility  for 
climate  or  local  conditions.  Other  suggestions  focused  on  simplifying  applications  (e.g. 
reducing documentation and unifying application systems and portals), recording and reporting 
(e.g. streamlining procedures and databases, or eliminating redundancy) and inspections (e.g. 
prioritising  support  over  strict  rule  enforcement).  Further  simplification  could  be  achieved 
through  better  communication  and  training  and  improved  use  of  digital  tools  (e.g.  remote 
sensing to reduce inspections, centralised platforms, or interoperability between IT systems). 
The most frequent piece of positive feedback on approaches taken or promoted by Member 
States concerned solutions involving digital tools and automation, SCOs and support for small 
farms.  

3. 

DESCRIPTION OF THE MEASURES AND THEIR IMPACTS 

The proposed package of amendments is guided by the objectives of reducing administrative 
burden, simplifying rules, improving the support to foster the competitiveness of EU farms, as 
well as ensuring a cost-effective delivery of the CAP’s objectives for the period 2023-2027, 
while maintaining its objectives.  

This section details the qualitative impacts and, where sufficient data are available, a limited 
quantitative  assessment  with  underlying  key  assumptions,  considering  the  uncertainties  and 
limitations,  estimating  the  reduction  of  administrative  costs15.  The  available  figures  are 
summarised in the Annex to this document.   

3.1  On-farm simplification and streamlining of requirements to better 

recognise various situations and farming practices 

Organic farmers’ compliance with selected GAECs  

This change entails a presumption that organic farmers are compliant with the requirements of 
GAEC  1  (maintaining  permanent  grassland  ratio  within  a  maximum  decrease  compared  to 
reference year 2018), GAEC 3 (ban on burning arable stubble), GAEC 4 (buffer strips), GAEC 
5 (tillage management), GAEC 6 (protection of soils in periods that are most sensitive) and 
GAEC 7 (crop rotation on arable land). This addresses the requests made by several Member 

15   Many  improvements  offer  farmers  additional  flexibility  or  economic  benefits  without  affecting  the 
administrative aspects. The uptake of  some of the measures depends on Member States and  then farmers’ 
decisions, both of which are difficult to predict in advance. Quantification is based on many assumptions and 
should be viewed as such. Isolating specific administrative costs is also difficult and limited availability of 
data impedes the robustness of the calculations. 

9 

 
 
 
States  and  the  sector,  and  further  responds  to  the  insights  on  GAEC  related  difficulties 
stemming from the survey about farmers and the ensuing study. 

The  organic  system  of  farm  management  and  food  production  combine  environmental  and 
climate action best practices mandated by EU organic farming legislation16. The objectives of 
GAEC standards 1, 3, 4, 5, 6 and 7 are protected through tillage and cultivation practices, the 
ban on the use of synthetic fertilisers and pesticides, limits on veterinary products and stocking 
density applied in organic production. A review of 31 synthesis papers on the environmental 
and  climate  impacts  of  organic  farming  systems  conducted  by  the  Commission’s  Joint 
Research Centre in 202117 indicates that organic farming systems have a significantly positive 
impact  compared  to  conventional  farming  systems  as  regards  carbon  sequestration  and  a 
reduced amount of nutrient leaching and run-off. Since organic farming legislation’s principles 
and  rules  as  well  as  the  existing  practices  under  organic  farming  systems  offer  comparable 
levels of protection, the impact of the amendment to the CAP’s green ambition is assessed as 
minimal. Even if the requirements of the organic farming legislation are not exactly matching 
those of the GAEC standards concerned, the combination of the existing requirements with the 
practices applied in organic farming will deliver the equivalent benefit in respect to the main 
objectives of those GAEC standards. 

This  measure  would  reduce  the  burden  for  organic  farmers  regarding  the  need  to  get 
acquainted with some of the obligations as well as to reflect those in the submitted application 
for  CAP  aid.  Besides  removing  the  efforts  and  costs  of  ‘duplicate  practices’  and  related 
paperwork,  the  measure  would  help  reduce  the  control  pressure  on  both  farmers  and 
administrations. This should also help reduce the related stress factors and allow more time to 
be spent on farm management or other tasks of the farmer’s choosing.  

Based on the results of the simplification study, farmers spend an average of 56 hours annually 
on preparing and submitting CAP aid applications, of which 9.6% is spent on administrative 
tasks related to conditionality and 56% of that time for other elements of aid application(s) (the 
remainder being recording and reporting)18. Taking these figures into account and estimating 
the number of organic farmers benefiting from CAP support to be 332 00019, this measure may 
reduce the related administrative costs for all organic farmers under the CAP  by up to EUR 
23.3 million annually. This is assuming that none of these farmers benefit from an exemption 
from the conditionality system due to the participation in the simplified payment scheme for 
small farmers.   

The reduction in the number of on-the-spot controls related to these GAECs, is estimated to be 
worth EUR 281 000 annually for organic farms above 10 ha that benefit from the CAP, based 
on the average estimated time reduced per control of 4,4 hours20 and taking 1% requirement 

16   Regulation (EU) 2018/848 
17   https://wikis.ec.europa.eu/spaces/IMAP/pages/44159076/Organic+farming+systems_GENERAL  
18   This assumption is supported by farmer experiences as surveyed under the simplification study and employs 
a methodological simplification to account for variances in those experiences, including the number of SMRs 
and GAECs applicable on an average farm. 

19   Latest  available  data  for  2022  financial  year  –  number  of  farmers  receiving  support  for  organic  farming 

measure (measure 11) under Rural Development.   

20   Expert  judgment  based  on  the  average  time  spent  on  a  single  on-the-spot  control  calculated  in  the 

simplification study (8,8 working hours) 

10 

 
 
 
for  inspection  of  conditionality21  of  195  000  organic  farmers  above  10  ha  (this  takes  into 
account that farms below 10 ha of agricultural area are already exempted from controls and 
penalties). 

At national administration level, cost reductions can be expected thanks to the lower number 
of items to be covered by administrative checks for these farmers and the reduced time it takes 
to conduct on-the-spot controls. Assuming a reduction by half the overall workload of eight 
hours per control for the 1% of 195 000 organic farmers above 10 ha22 (including preparatory 
steps and follow-up), this results in estimated saving of EUR 255 000 annually in 27 Member 
States for these farmers. 

GAEC standards and mandatory requirements established under national laws 

Feedback  from  farmers’  organisations  and  Member  States  indicated  that  certain  practices 
required under GAEC standards overlap with mandatory national requirements. This leads to 
confusion  about  which  rules  are  applicable  and  concerns  over  potential  consequences  of 
misapplication. A similar concern was identified in relation to the definition of ‘water courses’ 
under GAEC standard 4 on buffer strips, which may also be defined in national legislation. 

To address these concerns and improve the consistency of requirements, the proposal provides 
that Member States may set the GAEC standards so that they are consistent with mandatory 
national requirements for as long as the latter are in line with the GAEC standards, and their 
main objectives laid down in the CAP Plan Regulation. For instance, if a Member State already 
has legislation that sufficiently protects peatlands and wetlands, these rules can be included in 
its CAP strategic plan under GAEC standard 2 and Member States do not have to set other 
practices for farmers. This logic also applies to the definition of watercourses under GAEC 4, 
where  it  will  be  possible  to  align  it  with  a  national  definition.  This  will  be  verified  by  the 
Commission in the CAP Plan amendment process.  

For farmers this may reduce the time spent learning about the different rules and uncertainty 
costs  with  fewer  stress  factors  linked  to  their  application,  while  still  fulfilling  the  main 
objectives  of the standards.  For national  administrations, certain  one-off efforts related to 
redesigning  of  CAP  Plans  may  be  needed.  This  may  also  ease  the  control  burden  for  both 
farmers and administrations. These benefits could not be quantified due to the lack of data. 

This  amendment  does  not  impact  the  CAP  green  ambition,  since  the  mandatory  national 
requirements should comply with the GAEC standards laid down in the CAP Plan Regulation. 

Permanent grasslands – definition and GAEC standard 1 

GAEC  standard  1  requires  Member  States  to  maintain  permanent  grassland  based  on  a 
(national, regional or individual23) ratio of permanent grassland to agricultural area that is to 
be compared to the reference year 2018. This is based on a framework definition of permanent 
grassland24 which provides that after five years or more a grassland area becomes permanent 
grassland.  Where  the  permanent  grassland  ratio  has  decreased  by  more  than  5%  from  the 

21   The minimum control rate required for conditionality 
22   Based on expert judgment 
23   As set by a Member State in its CAP Plan. 
24   Laid down in Article 4(3), point (c) of the CSP Regulation 

11 

 
 
 
reference year 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 that had been converted from permanent grassland to other agricultural uses.  

The simplification package of 2024 introduced certain flexibilities in the way Member States 
can manage the ratio25. The feedback received from farmers’ organisations and Member States 
indicated  that  further  changes  are  needed  to  respond  to  changing  agronomic  and  climatic 
circumstances and to reduce unintended side effects of this standard.  

The legislative proposal modifies two inter-related elements concerning permanent grassland. 
It allows Member States to increase the time limit for the land to become permanent grassland 
from five up to seven years. It also changes the maximum percentage of the decrease of the 
ratio of permanent grassland from 5% to 10% compared to the reference year.  

This  change  would  increase  flexibility  in  grassland  management  for  farmers,  taking  better 
account of the needs of the livestock farmers, recognising better those who maximise grass in 
their  livestock  feeding  and  crop  rotation  systems.  This  approach  helps  farmers  to  avoid 
unnecessary ploughing just to avoid that the area concerned falls under the permanent grassland 
designation, thus preserving soil health, and avoiding costs of ploughing operations along with 
the  related  administrative  tasks  and  frustration.  This  should  also  help  focus  protection  on 
environmentally  most  valuable  and  permanent  grasslands  and  enable  the  recognition  of 
grassland management practices that benefit the environment and carbon storage.  

Adjustments in the maximum decrease of the permanent grassland ratio should further help 
reduce  uncertainty  and  worries  about  a  farm’s  economic  viability  that  farmers  face  when 
converting permanent grassland to adjust to market demand, and improve the diversification 
of fodder in the event of recurring drought on permanent grasslands. Changing the definition 
of permanent grassland is expected to have a stabilising effect on the ratio, as such permanent 
grasslands are generally less prone to changes in land use. 

Considering data gaps in terms of area and the number of farmers with grasslands of different 
age,  and  uncertainty  as  regards  Member  States’  and  farmers’  choices,  it  is  not  possible  to 
conduct a quantitative assessment related to administrative costs. However, it can be assumed 
that having a permanent grassland requirement that is not fulfilled after just five years is more 
favourable for farmers in accommodating different management practices and crop rotations, 
and  would  also  translate  into  reduced  administrative  burden  as  regards  filling  in  CAP 
applications and being subject to potential controls. 

At national administrations’ level, changes in the framework definition involve the need for 
a one-off administrative action in the short term given the need to adjust the definitions in the 
CAP  Plans  and  adjust  the  calculation  of  the  permanent  grassland  ratio  for  the  purposes  of 
GAEC  standard  1.  However,  this  could  be  offset  by  the  reduction  in  administrative  burden 
associated with processing cases that involve areas which fall under the current requirements 
under the permanent grassland definition after five years. Changes in the allowable decrease of 
the ratio create no specific administrative burden for national administrations and no burden 
for farmers.  

25   By amendment to Delegated Regulation (EU) 2022/126. 

12 

 
 
 
 
 
GAEC standard 2 (peatlands and wetlands) 

Under this GAEC, Member States are required to set up land management practices that protect 
carbon-rich soils, wetlands and peatlands, as they store substantial amounts of carbon and their 
protection  helps  avoid  emissions.  Their  presence  varies  widely  across  Member  States.  The 
standard was to be fully implemented from claim year 2025, once Member States completed 
the necessary mapping. All Member States have by now established such requirements in their 
CAP  Strategic  Plans.  The  experience  and  insights  gained  to  date  have  indicated  certain 
economic  burden  and  technical  difficulties  in  applying  GAEC  2,  as  reflected  in  the  many 
proposals for change from Member States and farmers’ organisations. 

The general solution set out in the Commission proposal for GAECs (explained above) allows 
Member  States  to  also  set  GAEC  2  requirements  consistently  with  mandatory  national 
measures, provided that the latter are in line with this GAEC standard and its main objective 
laid  down  in  the  CSP  Regulation.  In  addition,  this  proposal  will  allow  Member  States  to 
compensate farmers for the costs incurred and income foregone in relation to implementing 
(some  or  all)  the  GAEC  2  requirements  through  eco-schemes  or  agri-environment-climate 
interventions. This  flexibility  recognises  that  certain  obligations  established  under  GAEC  2 
may  be  costly  for  farmers  and  involve  production  limitations,  with  an  ensuing  impact  on 
income and economic viability of farms, and do not affect all farmers in the same way. This 
depends  on  the  extent  to  which  a  farm  will  be  impacted  by  the  presence  of  wetland  and 
peatland.  

There is no data to support a quantitative assessment (areas, farmers concerned and Member 
States’  decisions  on  requirements  and  financial  support).  However,  a  better  alignment  with 
existing national requirements on how to farm these soils and compensation for the entailed 
technical and economic efforts should simplify a farmer’s daily work, reduce administrative 
burden related to their CAP application and potential controls, and address the income related 
concerns and related stress factor.  

For national administrations, certain one-off efforts related to the redesign of CAP Plans can 
be expected in cases where new schemes may be offered. However, there are already support 
schemes on grasslands in Member States, where farmers affected by GAEC 2 were not able to 
participate  because  the  practices  supported  where  part  of  the  baseline.  In  this  case,  these 
farmers could simply apply for such support without any change in the CAP Plans. 

Exemption  of  small  beneficiaries  other  than  farmers  from  conditionality  controls  and 
penalties 

This measure extends to small beneficiaries supported under EAFRD, such as land managers, 
the same exemptions  from  conditionality controls and penalties currently available to  small 
farmers, in order to ensure level-playing field and non-discrimination among recipients of CAP 
aid.  The  area  managed  by  these  small  beneficiaries  other  than  farmers  is  limited  and  the 
administrative burden linked to the controls and application of penalties for not complying with 
conditionality  requirements  can  be  disproportionately  high  for  beneficiaries  and  Member 
States’ administrations.  

13 

 
 
Compensation for compliance with certain requirements imposed by national law going 
beyond conditionality 

The  proposal  enables  Member  States  to  compensate,  by  means  of  eco-schemes  or  agri-
environment-climate  commitments,  the  costs  borne  by  farmers  that  stem  from  national 
legislation  if  they  go  beyond  the  minimum  requirements  set  in  EU  law.  So  far,  such 
compensation was only possible for new national legislation during the first 24 months after 
the  new  legal  standard  becomes  compulsory  for  farmers;  the  modification  extends  this 
possibility.  

that  are  shouldered  by  farmers  and 

This modification should help Member States increase ambition in the areas of environment, 
climate, animal welfare and anti-microbial resistance, while allowing for compensation to take 
into account the potential additional costs of or income losses (opportunity costs) due to these 
requirements 
land  managers.  For  national 
administrations, this extension potentially reduces administrative costs that would otherwise 
have to be borne to change the concerned interventions (eco-schemes or agri-environmental-
climate  commitments)  to  exclude  the  amount  of  the  support  related  to  these  mandatory 
practices.  The impacts of these measures cannot be quantified due to lack of data (including 
details of Member States’ national laws, decisions to apply this measure and farmers’ uptake) 

Allowing funding for investments to bring farms up to new legal standards   

This change extends from 24 to 36 months the period during which support may be granted for 
investments contributing to compliance with new requirements imposed by EU law, with the 
period starting from the date when new requirements become mandatory for the holding. By 
way of providing additional support for young farmers in setting up their holdings, the start of 
the 36-month period for investments may be granted from the date the holding is set up or until 
actions outlined in the business plan are completed.   

Allowing  payments  per  livestock  units  and  beehives  for  agri-environment-climate  and 
organic farming interventions 

Currently, payments under eco-schemes can be granted per animal (livestock unit, (LU)) for 
schemes contributing to animal welfare, antimicrobial resistance and climate change actions. 
In contrast,  except  for animal  welfare,  agri-environment-climate commitments (AECC) and 
commitments  for  organic  farming  can  only  be  paid  on  a  per  hectare  basis,  which  makes  it 
difficult to design herd management actions.26 This is reflected in CAP Plans as only  a few 
Member States provide LU payments for climate-related commitments in their CAP Plans due 
to these regulatory constraints, which limit considerably the scope for CAP support, as reflected 
in the low value (2.16% of EU LUs) of the target for result indicator R.13 (reducing emissions 
in the livestock sector)27.  

26   Articles 31 (eco-schemes) and 70 (AECC) of Regulation (EU) 2021/2115 
27   Only seven CAP Plans have programmed eight eco-schemes linked to this result indicator, including practices 
to ensure outdoor grazing and adaptation of feed management. One Member State programmed one AECC 
intervention  covering  practices  that  involve  feed  quality  improvements  and  feeding  plans  for  cattle  and 

14 

 
 
 
 
The  Commission  proposal  involves  aligning AECC  with  eco-schemes  in  terms  of  allowing 
payments  per  LU,  to  support  interventions  targeting  climate  action,  as  well  as  providing 
management commitments or eco-scheme support for organic livestock. To increase support 
for beekeeping under both types of intervention, the proposal provides for a possibility to make 
payments for beehives. 

Due  to  the  lack  of  supporting  data  (e.g.  on  Member  States’  choice  for  inclusion  of  this 
instrument, or on farmers’ uptake of this measure compared to the current situation), it is not 
possible  to  quantify  the  impacts.  However,  these  measures  will  support  Member  States  in 
delivering increased financial support for these environmental and climate-related purposes.  

This would allow Member States to simplify, broaden and better target funding opportunities 
for farmers, such as those for feeding plans, feed additives, farm/grass-based feed management 
to reduce greenhouse gas emissions, also for improved herd management, which will improve 
the farmers understanding of the CAP support and simplify its management. The payment for 
beehives  might  allow  design  of  further  interventions  to  support  sustainable  apiculture,  for 
which an area-based payment does not fit the purpose.  

This will also bring reduced administrative work for national administrations compared to 
calculating support per hectare for livestock-related actions, since it would avoid the use of 
conversion rates, to calculate the support per hectare. Similarly, the possibility to pay support 
for  beehives  under  both AECC  and  eco-schemes  would  ease  the  planning  of  interventions 
supporting beekeeping beneficial for biodiversity (pollination).  

Risk management tools 

The CAP legislative framework provides for risk management instruments to help farmers cope 
with market risks and crises related to agricultural production. However, Member States have 
only used these instruments to a low extent, targeting 15% of EU farms overall, and there has 
been a certain lack of flexibility to cater for the situation of certain groups of farmers or areas 
with particular needs.  

The proposed legislative changes will allow young farmers and other entrants that have only a 
short or no production history to benefit from support, and allow more appropriate calculation 
methods for farmers with specific crops (permanent crops) or other justified cases. In addition, 
Member States would also be able to introduce a more selective (targeted) approach to using 
the share of direct payments to finance farmers’ risk management contributions.  

These changes will make risk management more accessible for farmers with specific needs. 
Overall, these changes should further help stabilise farmers’ income in the event of severe loss 
of  production  or  farm  income.  It  is  not  possible  to  quantify  of  the  effects  of  these  changes 
because of the lack of data either at the level of farmers or national administrations where, 
as a minimum, one-off administrative costs related to the redesign of the CAP Plans would be 
expected. 

fattening pigs, but it had to design the support as a lump sum payment per group of beneficiaries according 
to herd size, to overcome the design limitation. 

15 

 
 
 
 
Crisis payments to farmers  

During  the  first  years  of  the  implementation  of  the  CAP  Plans,  natural  disasters,  adverse 
climatic  events  or  other  catastrophic  events  severely  impacted  many  farmers’  production 
around Europe.  

The  agricultural  reserve  has  been  increasingly  used  for  alleviating  the  situation  of  farmers 
suffering direct losses due to such events, beyond its intended purpose (addressing impacts of 
market disturbances). In view of the mounting challenges faced by the EU agricultural sector, 
including trade tensions and geopolitical uncertainty, it is appropriate to refocus the reserve on 
its original purpose and explore other mechanisms to tackle catastrophic events.   

Therefore,  it  is  proposed  to  complement  the  CAP  toolbox  with  new  optional  types  of 
intervention to help farmers sustain crises. This will allow the Member States to use CAP 
funding for compensation payments to farmers in emergency situations where natural disasters, 
adverse climatic events or other catastrophic events, such as animal health diseases or plant 
pests, result in a production loss of at least 30 %. To this end, Member States would be able to 
allocate a maximum 3% of the annual CAP Plan funding to help farmers cope with the effects 
of such events. To recognise efforts already made by farmers, Member States would have to 
provide a higher rate of compensation to those who are insured or are covered by another risk 
management tool. It would also be up to Member States to decide whether to mobilise EAGF 
or EAFRD funds or both. However, to incentivise them to use EAGF funds for this purpose, 
an amount equivalent to 4% of the annual CAP funding may be allocated only if the EAGF, 
not  the  EAFRD,  is  used  to  fund  this  support.  In  addition,  Member  States  would  be  able  to 
supplement EAGF support with an equivalent 200% in additional national financing (for the 
EAFRD there is no such limit).   

In years where no natural disasters or other catastrophic events occur, any unspent funds will 
be managed according to the rules for each fund: the unallocated EAGF funds will be disbursed 
as  BISS28,  while  the  EAFRD  funds  may  be  allocated  to  other  types  of  rural  development 
interventions. The impacts of this change cannot be quantified due to the lack of data that could 
support  this  type  of  assessment,  and  the  fact  that  events  triggering  payments  cannot  be 
foreseeable upfront.  

These  new  types  of  intervention  -  allowing  Member  States  to  disburse  crisis  payments  to 
farmers  -  can  be  expected  to  result  in  less  time  to  return  to  pre-crisis  levels  of  operation. 
Confidence  in  preserving  farmers’  incomes,  and  livelihoods,  should  help  reduce  stress  in 
difficult situations. The proposal excludes this payment from the scope of application of the 
(social) conditionality system. As a result, for farmers who would be subject to a reduction of 
payments based on conditionality, crisis payments that were paid  to  alleviate  their situation 
following an important loss of production would not be reduced. 

Certain administrative costs are expected to fall on national administrations when they revise 
their CAP Plans and on farmers when they apply for this crisis payment.  

Using  this  possibility  would  require  redistribution  of  budgetary  resources  within  the  CAP 
Plans, to farmers severely affected by consequences of natural disasters from those not affected. 
This  is  because  reallocating  funds  to  these  new  crisis  payment  measures  will  reduce  the 

28   Basic income support for sustainability 

16 

 
 
 
indicative financial allocations for other interventions of Member States’ choice. However, the 
existing  ring-fencing  obligations  for Member States, such as those for the environment  and 
climate or young farmers, remain in place, thus this potential reallocation will not affect these 
ambitions.  

3.2. 

Streamlining support for smaller and medium-sized farms 

Simplified payment scheme for small farmers 

The existing simplified payment for small farmers, by replacing all direct payment types of 
support with a lump sum, helps reduce administrative burden linked to the application process 
and payments. Farmers find  applications  for direct  payments  complex  which is  a particular 
issue for smaller farms with limited administrative capacity. However, so far, the use of the 
current simplified scheme for small farmers has so far been rather limited, only six Member 
States have offered this form of support in their CAP strategic plans, covering 314 000 farms 
altogether. 

Therefore, it is proposed to widen the scheme’s approach, while retaining its voluntary use by 
Member States, so as to increase the attractiveness for Member States to offer it and for farmers 
to take it up. To this end, the maximum payment (lump sum) for small farmers will be increased 
from the current EUR 1 250 to EUR 2 500 (which roughly corresponds to the EU average direct 
payment  support  per  10  hectares)29.  Moreover,  Member  States  will  have  the  possibility  to 
decide whether this lump sum payment replaces the payments under eco-schemes. Finally, the 
beneficiaries of the payment will be exempted from the conditionality system. However, this 
exemption  will  not  affect  the  baseline  for  eco-schemes  and  agri-environmental-climate 
commitments, which these farmers would take up together with the payment.   

While it is for Member States to define a small farm under this scheme, it is assumed here for 
the purpose of the quantification that farms of no greater than 10 ha in size would constitute a 
small farm (there are approximately 3.7 million such farms in the EU 27 out of 5.8 million all 
farms - CAP beneficiaries).  

Considering  that  the  agricultural  area  managed  by  such  farms  is  limited  (10%  of  EU 
agricultural land overall), applying the system of conditionality to small farmers, who manage 
majority  of  farms  in  the  EU  (65%  of  CAP  beneficiaries),  yielded  no  significant  benefits  as 
regards its objectives while imposing costs, as well as substantial administrative burden, were 
imposed on these farmers. As these farms are already exempted from conditionality controls 
and  penalties,  the  modification  would  also  lift  a  certain  ambiguity  with  little  effect  on  the 
environment. The coverage will likely be smaller as not all Member States will likely take up 
the measure and cover all small farms defined above. 

For farmers, greater use of the payments for small farmers should reduce the time they spend 
on administrative tasks as fewer items need to be provided when filling in an aid application 
for  support  and  there  is  no  need  to  prepare  for  or  provide  documentation  related  to 
conditionality.   

29   https://agriculture.ec.europa.eu/system/files/2023-06/approved-28-cap-strategic-plans-2023-27.pdf  

17 

 
 
 
To quantify the potential benefits of this amendment, an estimation has been carried out based 
on the following assumptions: firstly, a substantial increase of the coverage by the scheme in 
the six Member States already using it; secondly, the potential addition up to six more Member 
States joining the scheme ( based on the interest in the instrument expressed by two additional 
countries for an increased lump sum, the share of small farms in these additional Member States 
and therefore potential interest in the scheme); thirdly, financial margin of manoeuvre for these 
countries to offer the scheme to the farmers. According to this estimation, 2.3 million additional 
farmers could benefit from the new scheme, with savings reaching around EUR 1.46 billion 
(taking into account the monetary value of the reduction in the time spent by the beneficiaries 
on submitting CAP aid application related to conditionality and for multiple direct payment 
schemes).  

The shift will also influence the redistribution of income support.  

For national administrations, one-off costs related to redesigning the CAP Plans to integrate 
this  instrument  are  expected.  Otherwise,  greater  adoption  of  the  payment  would  lower  the 
workload  related  to  collecting  and  processing  CAP  aid  applications,  thanks  to  fewer 
administrative checks to conduct and the lower complexity involved regarding these payments.  

The figures on administrative costs borne by Member States under the current CAP are not 
available. A rough estimate can be made by relying on the calculation of administrative costs 
for the administration of the Integrated Administration and Control System (IACS) in a 2018 
study  on  administrative  burden  arising  from  the  CAP30,  which  estimated  the  total 
administrative costs of the IACS borne by Member States to be 3% - 3.3%, of which 64% were 
linked to administrative checks of aid applications, and applying it to the overall annual CAP 
budget  under  CAP  Plans,  and  further  assuming  a  reduction  by  half  in  unitary  costs  per 
participating farmer. The reduction of administrative costs thanks to the introduction of this 
measure  in  the  case  of  the  above  assumptions  for  participating  Member  States  and  farmers 
would bring in up to EUR 209 million annually. 

Excluding eco-schemes payments from the maximum limit from the simplified payment might 
entail a certain level of increase in a national administration’s work linked to the application 
procedures and control of compliance with the baselines for those interventions. However, this 
change ensures that small holdings would have equitable access to eco-scheme benefits and 
would enable them to participate in order to increase their environment and climate efforts as 
well as empower them to cope with the specific challenges they face.  

3.3.  Measures to boost competitiveness 
Farmers consider the applications for CAP investment-related support to be among the most 
complex. The processes for submitting application for support and for implementing operations 
sometimes involve disproportionately high administrative effort in relation to the amount of 
public  money  spent,  especially  for  small  operations  (e.g.  collection  of  evidence,  proof  of 
reasonableness of cost). At the same time, existing flexibility on the rules and conditions for 
investment and other interventions that is already available to Member States, such as the use 

30   European Commission: Directorate-General for Agriculture and Rural Development and ECORYS, Analysis 
report,  Publications  Office, 

the  CAP  –  Final 

of  administrative  burden  arising 
2019,  https://data.europa.eu/doi/10.2762/521652  

from 

18 

 
 
 
of SCOs, is not fully utilised. These issues have been raised repeatedly by stakeholders, for 
example in the CAP Network’s thematic group on simplification. 

Investments and small operations 

Under the proposal, Member States have a new option to offer farmers of small holdings a 
lump sum payment of up to EUR 50 000 for business development. It will also be clarified 
that the calculation methods for SCOs established in the Common Provision Regulation31 and 
used in other EU policies for similar type of operations can be used directly under the CAP. 
This should encourage Member States to make greater use of such ‘off-the-shelf‘ SCOs for the 
benefit of CAP beneficiaries.  

SCOs  allow  the  reimbursement  of  expenditure  according  to  predefined  methods  based  on 
process, outputs or results. SCOs in general may take the form of flat rate financing, standard 
scales  of  unit  costs,  and  lump  sums.  SCOs  allow  the  tracing  of  co-financed  expenditures 
without the need to provide individual supporting documents. As such, significantly reducing 
the administrative burden for both managing authorities and beneficiaries32. 

Proposed  changes  would  make  support  more  accessible  for  the  under-resourced  group  of 
beneficiaries  such  as  small  farms.  It  would  also  be  easier  to  apply  for,  reducing  proof  of 
evidence, simplifying paperwork and procedures for filling in applications and reducing the 
time spent in collecting supporting evidence and price options. It may also reduce dependence 
on external advice for this purpose and be easier for Member States to implement.  

In the past CAP period some 150 000 small farms were to receive start-up aid support for farm 
development. Assuming that the level of interest in the current period is the same and an equal 
uptake of the measure every year of the 5-year CAP period, assuming this measure would be 
taken up in two years in the current CAP programming period, this would equate to a take-up 
of  this  proposed  measure  by  approximately  30  000  farms  annually.  Further  assuming  these 
farmers would therefore not use external advice to apply for support (an assumed cost of EUR 
50033), this would allow farmers to save EUR 15 million annually in administrative costs.   

At  the  same  time,  using  these  options  would  reduce  the  administrative  costs  for  national 
administrations of requesting and verifying the costing for a variety of different operations 
that can be funded. Data to quantify these benefits are not available. However, experience with 
the introduction of SCO shows34 its considerable potential; in the case of EAFRD for the period 
2014-2020 adopting this approach was estimated to have reduced administrative costs of the 
fund between 1.1% and 1.6 %.  

Financial instruments 

The evidence collected shows that access to financial instruments is limited for various groups 
of farmers in  need (e.g.  young farmers, farmers in difficulty such as livestock farmers,  and 

31    Regulation (EU) 2021/1060 
32   https://european-social-fund-plus.ec.europa.eu/en/simplified-cost-options  
33   Based on the information provided by farmers participating in the 2024.  Median cost of external advice for 

application for investment, for the participating farmers that provided this figure. 

34   European Commission: Directorate-General for Regional and Urban Policy, Spatial Foresight, SWECO and 
t33, Use of new provisions on simplification during the early implementation phase of ESIF – Final report, 
Publications Office, 2017, https://data.europa.eu/doi/10.2776/76513 

19 

 
 
 
farms  in  transition)  owing  to  financial  constraints,  high  levels  of  risk  associated  with  the 
farming activity and reduced  administrative capacity  to  use such instruments. The financial 
instruments of the CAP remain underutilised. Besides these limitations, the instrument’s audit 
framework is also unclear, which does not build confidence in using the tool to its full potential. 
Several Member States have called for this issue to be looked into.  

To tackle the above bottlenecks, the proposed changes to the legislative framework increase 
the  working  capital  gross  grant  equivalent  ceiling  for  access  to  finance  through  financial 
instruments to EUR 300 000, especially for farms in need and in line with the changes in the 
general  de  minimis  State  aid  regime,  as  well  as  by  ensuring  the  eligibility  of  VAT  for  the 
projects, as is also the case in other shared management policies and in the CAP pre-2023. The 
arrangements for auditing and sanctions will also be aligned with financial instruments of other 
EU shared management funds.  

Although it is not possible to quantify the benefits of these measures because of limited data, 
these changes would allow farmers to receive higher amounts (e.g. by 30%) of loans for their 
working capital needs, facilitate investment plans and reduce financial burden as a result of the 
VAT retained. Extrapolating the interest in this tool from the previous CAP period, it would 
mean that some 25 000 to 30 000 farmers, at least, could potentially be supported by financial 
instruments and therefore benefit from these changes.  

In addition, by improving consistency, these changes could also encourage Member States to 
increase spending  through financial instruments,  or through financial instruments  combined 
with  grants.  They  should  help  to  simplify  audits  and  control  requirements  for  farmers  and 
reduce the administrative burden for administrations; it should be noted that 12 Member States 
have already programmed financial instruments under their CAP Plans. 

Support for the fruit and vegetables sector 

Producer  organisations  and  their  associations  play  an  important  role  in  strengthening  the 
position of farmers in the supply chain. Support from the CAP is critical to address specific 
issues and sectoral objectives or to reward beneficial practices. The feedback received by the 
Commission from Member States and farmers’ organisations showed that there is a need to 
increase possibilities for this support.  

The proposed amendment to the legislation allows to increase the top up of 0.5% maximum 
amount of CAP support for operational programmes for the fruit and vegetables sector as long 
as  the  excess  amount  is  spent  on  the  objectives  focusing  on  research  and  innovation,  agri-
environment-climate,  consumption  and  resilience  objectives,  or  further  supporting  the 
economic viability of producer organisations/associations (rather than a requirement to cover 
multiple objectives simultaneously).  

This increase of a potentially available budget of producer organisations/associations does not 
seem to have any specific administrative effect in terms of reducing costs for those farmers 
concerned,  although  the  additional  financial  incentive  is  expected  to  lead  to  greater 
participation in operational programmes and therefore support the sector further. A one-off cost 
for national administrations for a redesign of the CAP Plan is to be expected. 

20 

 
 
 
 
Digital enhancement for reduced reporting burden and better use of data 

Evidence indicates that repeated reporting of the same information is a widespread inefficiency 
among the farming community and other CAP beneficiaries. A number of farmers and other 
CAP beneficiaries that were surveyed and interviewed recommended introducing unified and 
centralised  data  submission  systems,  pre-filled  forms,  and  centralised  cloud  storage  to 
eliminate redundancies and streamline processes. Enabling farmers to input farm parameters 
would  also  make  it  easier  for  them  to  track  compliance.  Some  Member  States  are  already 
moving  in  this  direction  and  are  investing  in  the  interoperability  of  public  and  private  data 
systems. 

The  legislative  changes  proposed  lay  the  groundwork  for  delivering  the  benefits  of 
digitalisation  to  farmers.  Member  States  will  designate  an  authority  to  prepare  a  roadmap 
clearly  setting  out  how  and  when  they  intend  to  achieve  and  maintain  the  necessary 
interoperability  between  public  agricultural  information  systems  used  for  implementation, 
monitoring and evaluation of the CAP.  

Once  implemented,  it  will  be  possible  to  exchange  data  seamlessly  between  those  systems, 
thereby reducing the number of requests for information directed at farmers and minimising 
the time they have to spend on collecting and providing data to the authorities. Ultimately, this 
should give farmers more time to focus on their core work. In addition, when data can be more 
easily integrated between different sources, farmers can make better use of the data to manage 
their farms better.  

Quantification of impacts has to be estimated with caution as the measure concerns preparatory 
steps that are needed to address the problem of multiple reporting and inefficient management 
of  data.  The  results  of  the  2024  survey  of  farmers  show  that  some  44%  of  farmers  report 
duplicate reporting (i.e. for various purposes, not just CAP related purposes, such as taxation 
and  financial  administration,  land  use/allocation,  environment-related,  pesticides,  animals 
etc.).  Excluding  those  that  did  not  answer  this  question  and  focusing  on  respondents  that 
indicated being CAP recipients brings this figure to 49% of them indicating duplicate reporting 
compared  to  non-CAP  recipients,  where  28%  indicated  the  same.  Therefore,  21%  of  that 
burden  can  be  assumed  to  come  from  the  CAP  (21%  of  farmers  that  are  required  to  report 
multiple times solely because of the CAP). Assuming the same applies to the whole population 
of  CAP  beneficiaries  (5.8  million),  elimination  of  one  duplicate  data  request  per  year,  and 
further assuming a farmer generally spends two hours dealing with every request35, the new 
measure, when implemented by Member States fully, could reduce administrative costs borne 
by farmers by at least EUR 77 million annually for all CAP beneficiaries.  

The  proposed  approach  is  based  on  Member  States’  self-assessment  of  the  needs  and  will 
enable  those  who  decide  to  advance  quickly,  to  reap  the  benefits  of  greater  digitalisation 
through faster data collection, lower associated costs, reduced risk of errors, and better input to 
policy design and implementation. The proposed approach allows the other Member States that 
need more time to deploy data governance and interoperability in their administration, to do so 
in a more gradual fashion, drawing inspiration from the experience of the pioneering Member 
States. 

35   Expert judgment 

21 

 
 
 
One-off  set-up  costs  associated  with  the  assessment,  drafting  of  the  roadmap  and  its 
implementation will be necessary. Assuming two staff members are engaged full-time for six 
months for the assessment and roadmap and any potential external input, the preparatory cost 
could  be  around  EUR  250  000  per  Member  State.  Costs  of  implementing  the  roadmap  are 
difficult  to  predict  as  they  depend  on  the  needs  identified  and  the  existing  degree  of 
digitalisation and interoperability, which varies among Member States. Recurrent benefits on 
both public and private sides will largely exceed the costs of implementation. For example, the 
fully  scaled  use  of  digitalisation  has  been  estimated  to  reduce  annual  maintenance  costs  of 
public authorities’ administrative systems by up to 50%36. 

Reducing pressure and burden on farmers and national administrations linked to data 
collection and keeping, controls and other on-farm visits linked to CAP management 

Evidence  shows  that  the  burden  of  inspection  (whether  under  the  CAP,  other  EU  laws  or 
national  legislation)  remains  quite  significant,  even  if  the  control  and  penalty  system  is 
designed by Member States. Besides, as regards the number of inspections and the time taken 
to prepare and follow-up on them, some farmers interviewed for the simplification study said 
that they could not understand the rules underpinning controls and did not know what to expect 
from  the inspections. They complained  about  a lack of  feedback  from  inspectors and  about 
mistakes  made by inspectors. Controls  can  become more burdensome  if inspections are not 
planned  sufficiently  well  to  avoid  overlapping  with  crucial  farming  activities  such  as 
harvesting.  

The  organisation  of  controls  is  now  left  up  to  Member  States  (except  for  certain  rules  on 
conditionality) who do not necessarily make use of all the flexibilities under the new approach. 
Several of the proposed actions would directly or indirectly reduce the need for controls. 

Simplification of IACS quality assessment and its methodology 

The proposed changes to the basic act would be to: 

•  merge  the  three  separate  quality  assessments  (QA)  for  the  land  parcel  identification 
system  (LPIS),  the  geo-spatial  application  (GSA)  and  the Area  Monitoring  System 
(AMS), which would make it possible to simplify further the Union-level methodology 
(ULM) for IACS quality assessment; 

•  provide  clarity  that  the  AMS  can  replace  the  need  for  a  control  system  for  fully 
monitored eligibility conditions (using free Copernicus Sentinel satellite data and AI 
for interpretation instead of on-site visits). 

For  farmers,  these  changes  will  reduce  significantly  the  number  of  on-farm  visits  national 
authorities need to make to perform the annual IACS quality assessment. The impact on the 
administrative  burden  cannot  yet  be  quantified.  However,  an  ongoing  study  to  assess  the 
reduction of on-farm visits will help to quantify the effects of these changes.  

Farmers will also benefit from the AMS replacing controls. It helps to bring about a shift away 

36   Daub, M., Domeyer, A., Lamaa A., and Renz, K. (2020, July 15). Digital public services: How to achieve 

fast transformation at scale. McKinsey & Company. https://www.mckinsey.com/industries/public-
sector/our-insights/digital-public-services-how-to-achieve-fast-transformation-at-scale#/  

22 

 
 
 
from penalising non-compliances towards preventing them as farmers can be contacted in cases 
of doubt and amend their application (without sanctions). It also helps to ensure equal treatment 
of  all  farmers  concerned  as  the  whole  population  is  now  being  monitored  and  given  the 
opportunity  to  adjust  without  any  consequences,  compared  to  a  limited  population  under 
control and potential penalties. This change should minimise the need for repeated inspections 
for  specific  interventions  with  limited  number  of  beneficiaries,  which  is  also  beneficial  for 
Member State administrations.  

It is not possible to quantify these benefits for farmers without the information on the number 
of  eligibility  conditions  concerned  and  the  beneficiaries  of  payments  affected  by  these 
conditions. For those interventions where the eligibility conditions are fully monitorable, no 
further on-farm controls are needed under the proposed system. A further analysis involving 
complete data from all Member States is intended to quantify the reduction of administrative 
costs.  

The changes will further reduce stress factors for farmers, as overall, a well-functioning IACS 
system allows farmers to apply for CAP support in an efficient manner, reducing sanctions, and 
to be paid support in an accurate and timely manner. Preliminary data from Member States’ 
paying agencies indicate a significant reduction in penalties depending on the interventions in 
Member States (i.e. from 45% to 89% for BISS in some Member States) as a result of the AMS 
being introduced. 

National administrations will benefit from a reduced workload in terms of the streamlined 
inspection  procedures  and  the  reduced  reporting  obligations  (i.e.  only  one  report  instead  of 
three). Additionally, when needed, Member States would be able to propose a single remedial 
action encompassing all three systems (i.e. LPIS, GSA and AMS), rather than implementing 
separate actions, thereby improving their efficiency. 

Single on-site visit 

The proposed change, which would require Members States to implement a single, on-the-spot 
control regime, could lead to further reductions in the number of on-farm visits and lessen the 
control burden on farmers.  

This means that a beneficiary selected for such a control will not be selected for a subsequent 
check and control sample for that year, except when the circumstances require a second control 
in order to ensure the effective protection of the financial interests of the Union. This change 
is in line with the suggestions raised, for example in the Thematic Group on simplification of 
the CAP Network. 

Quantification of the impact of this change is not possible due to the absence of relevant data. 
However, a reduction of each on-site-visit was estimated to bring reduction of administrative 
costs of approximately EUR 288 per farm on average. 

3.4.  Greater flexibility to Member States in the management of CAP 

Plans 

Amendments to CAP Plans 

Experience  has  shown  that  amendments  to  CAP  Plans  often  include  numerous  technical 

23 

 
 
elements that make them complex and onerous for Member States, and result in delays in the 
approval  procedures,  even  though  the  strategic  orientation  of  the  plans  remain  unchanged.  
Notifications by the Member States to modify the CAP Plans, as applicable under the current 
rules, must be subsequently approved by the Commission, which can lead to uncertainty and 
delays in implementation of the amendments. Diverging rules for amendments of CAP Plans 
across  the  two  funds  (the  EAGF  and  the  EAFRD)  also  make  the  system  cumbersome  and 
unresponsive to changing circumstances (as the rules for EAGF are more rigid). This interferes 
with the timely and effective adaptation of CAP Plans to changing economic realities and the 
needs  of  farmers  and  other  beneficiaries  in  Member  States;  it  also  impacts  negatively  the 
implementation of those plans. This was also reflected in the feedback from Member States 
and the farmers’ community. 

To address this the legislative proposal provides for: 

•  differentiation  of  amendments  of  CAP  Plans  between  the  strategic  ones,  subject  to 
Commission  approval,  and  other  amendments,  which  Member  States  may  apply  upon 
notification to the Commission and which the Commission is not approving. For the non-
strategic amendments, the Commission can object if the amendment is not in line with the 
CAP  legal  framework. The  strategic  ones  concern  only  important  elements  of  the  CAP 
Plans, defined in the proposed text, such as amendments to introduce new interventions or 
delete  existing  interventions,  transfers  of  financial  allocations  between  the  EAFRD  and 
EAGF,  maximum  and  minimum  financial  allocations,  and  as  amendments  that  lead  to 
changes of milestones or targets under the result indicators which are marked with ‘PR’ (for 
performance review) in Annex I to the CSP Regulation.   

•  alignment  of  the  rules  for  amendments  of  EAGF  with  those  of  EAFRD,  so  that  the 
Member States may set the date of eligibility and the date of effect (for strategic EAGF-
related amendments) on the date on which a Member State submits a request for the CSP 
amendment to the Commission. This means that the Member States do not need to wait for 
Commission approval of the strategic EAGF related amendment (as it is currently the case) 
before they start implementing the amendment, however they implement the amendment 
at their own risk, since if the Commission does not approve the amendment the expenditure 
will not  be eligible for  a contribution  from  the EAGF or the EAFRD,  respectively. The 
Commission should reject the amendment if it is not compatible with the CAP Union legal 
framework.  Furthermore,  to  promote  realistic  and  inclusive  planning  of  amendments  in 
respect to beneficiaries, it is proposed to oblige Member States to obtain an opinion of the 
monitoring committee37 on the planned dates of effect of the strategic amendments related 
to the EAGF. 

This  is  a  significant  step  in  giving  Member  States  more  flexibility  to  implement  quickly 
changes to their CAP Plans, particularly for changes funded through the EAGF. 

For  farmers,  the  changes  should  make  the  process  more  predictable  by  reducing  the 

37   Monitoring  committees  are  set  up  by  each  Member  State  to  monitor  the  implementation  of  CAP  Plans. 
Composition of a national monitoring committee must ensure a balanced representation of the relevant public 
authorities and intermediate bodies, including regional and local authorities and competent authorities for 
environment and climate, representatives of economic and social partners, including those of the agricultural 
sector, and other bodies representing civil society. Monitoring committees have an advisory function and their 
role is to facilitate the channelling of the views of stakeholder into the CAP Plans’ implementation process.  

24 

 
 
 
uncertainty related to the length of the approval process. Alignment of the date of eligibility for 
expenditure related to amendments to CAP interventions funded from both the EAGF and the 
EAFRD will help in improving synergies among interventions for Member States, in particular 
for those financed from different funds. The obligation to obtain an opinion of the monitoring 
committee  will  further  increase  predictability  and  ensure  that  the  representatives  of 
beneficiaries  (farmers) are involved in  planning the date of  effect  for strategic amendments 
related to the EAGF.  

For national administrations, simplification in planning is expected since the proposed dates 
of  eligibility  of  expenditure  for  most  amendments  will  be  known  already  at  the  time  the 
amendments  are  submitted.  This  will  increase  substantially  the  margin  of  manoeuvre  for 
Member States, particularly for interventions where regular adaptations are needed to ensure a 
good  uptake,  such  as  eco-schemes,  while  maintaining  the  requirement  for  ring-fencing. 
Currently, the time needed to adapt eco-schemes is usually quite long and unpredictable as it is 
usually influenced by the overall time needed to approve all amendments submitted in a request 
for  amendment.  This  greater  flexibility  entails,  however,  a  certain  element  of  risk  for  the 
Member  States  if  the  changes  are  subsequently  not  approved  by  the  Commission  (strategic 
amendments) or if the Commission objects to them (other amendments).  

It is not possible to quantify the benefits of this due to a lack of data. 

Annual Performance Clearance  

All Member States requested either changes to this process or its abolition, given that it entails 
a need for multiple justifications of deviations from the planned unit amounts for interventions.  

The discontinuation of the annual performance clearance exercise will reduce administrative 
costs and time spent by national administrations on preparing justifications of amounts spent 
at the level of individual units and on reporting these to the Commission. The efforts saved can 
be devoted to  other activities i.e. assistance to  farmers. At the same time, assurance on EU 
expenditure  is  achieved  by  the  requirement  for  an  effective  operation  of  Member  States’ 
management  and  control  systems,  assessed  as  a  part  of  the  conformity  procedure.  The 
Commission  will  continue  assessing  the  annual  performance  report  and  carrying  out  the 
biennial performance review to verify performance of the CAP Plans on the basis of milestones 
and targets under result indicators.   

Member States were asked to  provide estimate on resources (time) saved  as  a result of this 
change.  Based on the information received and counting a cost of labour of EUR 32.70 per 
hour, there would be an overall cost saving of EUR 324 550 per year. 

While  this  change  will  have  no  direct,  quantifiable  benefit  for  farmers,  a  reduction  in  the 
burden  for  administrations  entailed  in  the  annual  performance  clearance  process  will  allow 
them to focus their time on resolving administrative or technical issues related to applications 
that do impact farmers and lead to delays in issuing payments.   

25 

 
 
 
 
Annual performance report and biennial performance review 

The legislative proposal extends the time limit for the Commission’s acceptance check of the 
annual performance reports (APR) submitted by Member States and clarifies the links between 
the content of those reports and the biennial performance review (BPR). 

Modification to these processes will bring more clarity and legal certainty to Member States 
and  result  in  less  administrative  costs  on  national  administrations  helping  to  facilitate  the 
implementation of the APR and BPR processes. More time for the comprehensive assessment 
of the APRs by the Commission will lead to clearer instructions for the Member States, and 
more time for technical  corrections by the Member States where needed. This will result in 
higher quality data reported by the Member States on what their CAP Plans have achieved.  

There  are  no  direct  benefits  for  farmers.  However,  they  will  benefit  indirectly  from  the 
improved implementation of the CAP Plans and from better acknowledgment of their efforts 
made.  

Methodology for designing controls of conditionality 

The control of conditionality is based on a system set up by the Member States with specific 
common  rules  defined  in  the  basic  legislation.  Experience  gained  in  the  application  of  the 
conditionality control system has shown that these conditions are excessively rigid and place 
an undue burden on Member States, without necessarily enhancing the protection of EU funds. 

The  Commission  proposal  deletes  the  obligation  to  include  weighting  factors  to  use  for 
selecting the risk-based part of the control sample and removes the obligation to perform an 
annual review of the control system.  

At Member States level this streamlining would mean that they would no longer be penalised 
for these specific  aspects  during audits, while still having  to  implement  an efficient  control 
system. The requirement to cover at least 1% of beneficiaries remains intact.  

This change would have no impact on farmers, as it would not involve any change in control 
or penalties. 

Link between CAP and other legislation 

Under the CSP Regulation, CAP Plans must contribute to, and be consistent with, the relevant 
EU laws on the environment and climate. These laws are listed in Annex XIII to the Regulation. 
Article 120 of that Regulation requires Member States to assess the need for amendments to 
their  CAP  Plan  after  modification  of  these  acts.  Article  159  of  that  Regulation  requires  the 
Commission to assess the need to update Annex XIII by the end of 2025. 

Such  strategic  modifications  in  the  middle  of  the  implementation  period  could  be  highly 
disruptive for national authorities and farmers, counteracting the simplification objective. 
Considering  the  strategic  choices  already  made  by  Member  States  in  terms  of  targets  and 
financial planning for the whole period, it would be inappropriate to revisit the CAP Plans for 
this reason. The proposed changes address the need for stability for administrations and farmers 
in terms of CAP support and obligations. Quantification of impacts is not possible. 

26 

 
 
 
 
4. 

CONCLUSIONS AND NEXT STEPS 

The  comprehensive  package  of  amendments  to  the  basic  CAP  legislation  set  out  in  the 
Commission proposal draws on the experience of more than two years of implementation of 
the  CAP  strategic  plans  and  responds  to  calls  from  the  farming  community,  the  European 
Parliament, the Council, and Member States to address urgently the administrative burdens and 
bottlenecks within the CAP legislative framework, while taking account of the concerns and 
expectations raised by other groups of stakeholders.   

The  package  steers  the  CAP  along  the  pathway  outlined  in  the  Commission’s  Vision  for 
agriculture  and  food,  enabling  a  balanced  transition  to  improved  agricultural  practices  and 
supporting  farmers’  business  development  opportunities,  especially  young  farmers.  It  offers 
substantial additional flexibility to both Member States and farmers and creates conditions for 
increased use of opportunities of the CAP legal framework. 

At its core, the proposed amendments acknowledge that incentivizing farmers may be more 
effective  than  imposing  changes  through  mandatory  requirements,  thereby  ensuring  greater 
acceptance and adherence to sustainability improvements. The simplification proposal keeps 
all the essential components of the CAP’s green architecture, including all GAEC standards 
and, CAP support instruments that will continue to be designed to go beyond the mandatory 
standards (except potentially one GAEC to take account of farmers’ income concerns). 

This staff working document provides, where possible, an indication of the quantitative effects 
of  proposed  simplification  measures  on  the  administrative  burden  borne  by  farmers  and 
national administration. It also employs qualitative assessment of measures, based on expert 
judgment.  Accordingly, the quantified measures are estimated to bring savings up to EUR 1.58 
billion per year for farmers and at least EUR 210 million for administrations. 

Overall, this assessment indicates that the package offers opportunities to significantly reduce 
CAP-related  burden,  especially  for  farmers,  even  if  the  effect  of  all  measures  cannot  be 
quantified. The cost-savings and benefits ultimately achieved and their distribution will largely 
depend on the choices made by Member States. The role of Member States in leveraging the 
new opportunities and achieving tangible simplification for farmers is key.   

To maintain the effectiveness and efficiency of the policy, the Commission will continue to 
support implementation of the CAP Plans, to pinpoint opportunities for future improvements. 
The Commission will continue its efforts to support collaborative learning and peer exchanges 
between Member State authorities and other stakeholders, in particular  farmers and farming 
organisations), and by facilitating the CAP Network's engagement. 

27 

 
 
 
 
 
ANNEX – Table of estimated savings for farmers and national 
administrations for quantifiable measures in the 27 Member States 

Measures included in the 
CAP Simplification 
proposal* 

Farmers 
(annual savings) 

Compliance of organic 
farmers with selected 
GAECs 

Related to 
applications 

Related to on-the-
spot-checks 

€23 million 

€281 000 

National 
administrations 
(annual savings) 

 €255 000 

Simplified payment 
scheme for small farmers 

Investments and small 
operations 
Digital enhancement 
Annual Performance 
Clearance  

 €1.46 billion 

 €209 million 

 €15 million 

 €77 million 

 €325 000 

TOTAL  

 €1.58 billion 

 €210 million 

*   Measures leading to additional savings for which quantification is not possible are not 

presented in this table. 

28