COMMISSION STAFF WORKING DOCUMENT Accompanying the documents Commission Delegated Regulation amending Delegated Regulation (EU) 2022/1172 with regard to the integrated administration and control system in the common agricultural policy Commission Implementing Regulation amending Implementing Regulation (EU) 2022/1173 laying down rules for the application of Regulation (EU) 2021/2116 of the European Parliament and of the Council with regard to the integrated administration and control system in the common agricultural policy Commission Implementing Regulation amending Implementing Regulation (EU) 2022/128 as regards the annual performance clearance, the multi-annual performance monitoring and the scrutiny of transactions Commission Delegated Regulation amending Regulation (EU) 2022/126 supplementing Regulation (EU) 2021/2115 of the European Parliament and of the Council with additional requirements for certain types of intervention specified by Member States in their CAP Strategic Plans for the period 2023 to 2027 and under Regulation as well as rules on the ratio for the good agricultural and environmental conditions (GAEC) standard 1
Date: 2026-01-21
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: administrative sanction, agricultural expenditure, aid to agriculture, common agricultural policy, eligibility criteria, financial control, geographical information system, information system, pesticide, simplification of formalities

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.1.2026  SWD(2026) 4 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the documents      Commission Delegated Regulation amending Delegated Regulation (EU) 2022/1172 with regard to the integrated administration and control system in the common agricultural policy                                                         Commission Implementing Regulation amending Implementing Regulation (EU) 2022/1173 laying down rules for the application of Regulation (EU) 2021/2116 of the European Parliament and of the Council with regard to the integrated administration and control system in the common agricultural policy                                                                              Commission Implementing Regulation amending Implementing Regulation (EU) 2022/128 as regards the annual performance clearance, the multi-annual performance monitoring and the scrutiny of transactions                                        Commission Delegated Regulation amending Regulation (EU) 2022/126 supplementing Regulation (EU) 2021/2115 of the European Parliament and of the Council with additional requirements for certain types of intervention specified by Member States in their CAP Strategic Plans for the period 2023 to 2027 and under Regulation as well as rules on the ratio for the good agricultural and environmental conditions (GAEC) standard 1 {C(2026) 281 final} - {C(2026) 283 final} - {C(2026) 267 final} - {C(2026) 371 final}  
 
 
1.  INTRODUCTION 

On 19 February 2025, the Commission adopted ‘A Vision for Agriculture and Food’1 setting 
out a pathway for the EU actions towards achieving an attractive, competitive, resilient, future-
oriented and fair agri-food system for current and future generations of farmers and agri-food 
operators. The Vision called for unnecessary bureaucratic and regulatory burden to be reduced, 
a key step to support the competitiveness of the farming sector and of the entire agri-food value 
chain, including a more streamlined and strategic implementation of the Common Agricultural 
Policy (CAP).  

On 14 May 2025, drawing on and responding to extensive feedback from  stakeholders,  the 
Commission  proposed  a  comprehensive  simplification  package  of  the  basic  legislation 
underpinning  the  current  CAP  (2023-2027),  that  is  the  CAP  Strategic  Plan  and  the 
Horizontal  Regulations2.  This  package3  delivers  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). With modifications, the proposal was 
adopted by the co-legislators and then published on 31 December 20254. 

This proposal was accompanied by a staff working document, documenting the stakeholders’ 
feedback  and  assessing  impacts  of  the  proposed  changes  on  administrative  costs  borne  by 
farmers and national administrations5.  

At the time, the Commission also published a roadmap6 to deliver additional improvements 
via the CAP’s secondary legislation. 

This staff working document (Section 2) provides an assessment of impacts on administrative 
costs resulting from simplification of the following: 

•  Commission Delegated Regulation amending Delegated Regulation (EU) 2022/1172 
concerning the integrated administration and control system (IACS) as regards the 
scope of the quality assessments of the geo-spatial application system and of the area 
monitoring system (changes to Articles 4 and 5 of this Delegated Regulation);  

•  Commission  Implementing  Regulation  amending  Implementing  Regulation  (EU) 
2022/1173  concerning  the  integrated  administration  and  CAP  control  system  as 

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 Regulation (EU) 2021/2115 and Regulation (EU) 2021/2116, respectively 
3 COM(2025) 236 final 
4 Regulation (EU) 2025/2649 of the European Parliament and of the Council of 19 December 2025 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 suspensions of payments, annual performance clearance and controls 
and penalties (OJ L, 2025/2649, 31.12.2025, ELI: http://data.europa.eu/eli/reg/2025/2649/oj). 

5 SWD(2025) 236 final  
6 Roadmap for simplifying the CAP legal framework to reduce burden on farmers and national administrations  
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regards the obligation to record the use of plant protection products in the geo-spatial 
aid application (change to Article 8(3)(f) of this Implementing Regulation); 

•  Commission  Implementing  Regulation  amending  Implementing  Regulation  (EU) 
2022/128  as  regards  the  scrutiny  of  transactions  (change  to  Article  46  of  this 
Implementing Regulation); 

•  Commission delegated Regulation amending Delegated Regulation (EU) 2022/126 as 
regards approval of operational programmes of transnational (associations of) producer 
organisations, market withdrawals, rules on marketing standards, and minimum control 
rate for hemp cultivation (changes of Articles 2, 22, 25, 26, 27, 28, 29, 32a, 33 and 48 
and Annexes I, V and VII). 

Where data for estimates was available, the impacts were quantified, otherwise the document 
provides a qualitative appreciation of burden reduction7. The available figures are summarised 
in the annex to this document. 

This  document  does  not  cover  other  adjustments  of  the  secondary  legislation  that  solely 
translate  the  simplifications  pursued  in  the  underlying  basic  act,  and  which  were  already 
assessed in the above-mentioned staff working document. 

2.  SIMPLIFICATION  MEASURES AND  THEIR  IMPACT  ON ADMINISTRATIVE 

COSTS 

2.1. Amending  Delegated  Regulation  (EU)  2022/1172  as  regards  the  scope  of  the 
quality assessments of the geo-spatial application (GSA) system and of the area 
monitoring system (AMS) 

The  main  IACS  components,  including  GSA  and  AMS,  are  subject  to  an  annual  quality 
assessment  to evaluate if  the IACS  is  achieving  its  aims,  and  to  improve  how  it  works (as 
regards the correct number of hectares for the CAP´s output and result indicators)8. 

The amendment introduces the following changes: 

•  Limiting  the  scope  of  AMS  and  GSA  quality  assessment  only  to  monitorable 
eligibility conditions, which will make it possible to simplify further the Union-level 
methodology  (ULM)  for  IACS  quality  assessment  and  considerably  reduce  the 
necessity of field visits. 

Impact on national administrations 

A quantification of the impact of this change relies on the provisional information provided by 
all  Member  States  as  they  report  their  IACS  quality  assessments’  results  in  QUAP  portal 
(Quality Assessment Platform): 

•  Number of eligibility conditions for area-based interventions under the current CAP 

Plans:  

7 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. 

8 For further information and previous improvements of this framework, see SWD(2024) 360 final of 10.12.2024 
2 

 
 
 
Overall,  Member  States  reported  6 500  eligibility  conditions.  This  represents  an 
average of 233 eligibility conditions per Member State (across 28 CAP Plans), but with 
differences  among  them  depending  on the design  of the interventions done by each 
Member  State  (for  instance,  ten  Member  States  have  more  than  300  eligibility 
conditions, while eleven Member States have fewer than 150). This figure provides a 
comparative  insight  into  the  design  of  the  interventions,  that  can  also  ultimately 
illustrate the greater or lesser burden of requirements that have been set. 

•  Rate of monitorable and non-monitorable eligibility conditions in the current design of 

CAP Plans:  

Overall,  54%  of  the  reported  eligibility  conditions  can  be  considered  monitorable, 
including administrative checks (carried out for all claimed parcels, and therefore in 
line with monitoring principles applied in AMS). In contrast, 46% were reported as 
non-monitorable,  requiring  field  visits  or  requesting  specific  documentation, 
performed on a sample of the population of claimed parcels. There is also a significant 
variability  among  Member  States:  nine  countries  have  more  than  90%  of  their 
eligibility conditions monitorable (four of them 100%), and three have less than 10% 
of  monitorable  eligibility  conditions.  This  figure  is  crucial,  since  it  allows  a  more 
accurate estimation of the intensity in the implementation of AMS. 

Number  of  claimed  parcels  with  at  least  one  non-monitorable  eligibility  condition: 
Based  on  the  figures  reported  by  all  Member  States,  the  number  of  parcels  in  the 
samples of IACS quality assessments is around 120 000. Those which have at least one 
non-monitorable eligibility condition requiring a field visit, or a similar task in terms 
of  workload,  amount  to  more  than  77 600  (65%).  This  figure  of  77 600  parcels 
represents  the  maximum  workload  that  could  be  saved  by  public  administrations. 
Whenever the quality  assessment  sample is  already part of the ‘on-the-spot  checks’ 
sample, the workload reduction is limited. However, a certain share of the monitored 
population of parcels would need field visits for the quality assessment exercise in case 
the result is not conclusive (i.e. cloud cover, very small parcels). An estimation between 
15-20%  of  field  visits  in  monitored  parcels  should  represent  a  conservative  share, 
according  to  the  current  capabilities  of  the  available  technology.  In  previous  years, 
between 84 000 and 86 000 parcels had field visits (77 600 + [15%/20%]*42 400), 
while for claim year 2026 only 18 000 to 20 000 would need to be visited. This leads 
to a final estimation of savings between 64 000 and 68 000 parcels not having to be 
inspected on the field. 

•  Saving of costs in the IACS quality assessment exercise:  

Taking  the  previous  element  into  consideration,  the  savings  could  vary  for  each 
Member State from EUR 11 000 to EUR 540 000 depending on the number of non-
monitorable eligibility conditions that are concerned. An estimation of around EUR 60 
per parcel inspected (or similar task), is considered, according to the field inspections 
daily gross cost of EUR 250 and an average rate of 4-5 parcels visited per day due to 
the scattered location of the parcels that are part of the quality assessment samples. 

3 

 
 
This represents a saving of EUR 3.7-4 million (i.e. an average of EUR 3.85 million) 
at  EU  level  when  this  simplification  enters  into  force  for  claim  year  2026,  which 
corresponds to more than 50% of the costs of performing IACS quality assessment in 
the previous years.  

Impact on farmers 

These changes will reduce significantly the number of on-farm visits that national authorities 
need  to  make  to  perform  the  annual  IACS  quality  assessment. It  is  currently  estimated  that 
more  than  21  000  farmers  are  involved  in  the  assessment  of  non-monitorable  eligibility 
conditions  every  year,  in  the  IACS  quality  assessment  exercise,  at  EU  level.  Consequently, 
these farmers will have more time to dedicate to their own work, as they will spend less time 
dealing with on-farm visits by national authorities. Note that, for those interventions where the 
eligibility conditions are fully monitorable, no further on-the-spot checks are needed under the 
proposed system. 

Overall,  the  proposed  simplifications,  combined  with  the  full  implementation  of  the AMS, 
would reduce stress factors for farmers as a well-functioning IACS system allows farmers to 
participate in CAP interventions in an efficient manner, reducing the likelihood of sanctions, 
and receiving financial support in an accurate and timely manner. 

The main objective of the amendment is to focus the quality assessment of the area monitoring 
system and the geo-spatial application only on monitorable eligibility conditions, which are 
defined in Article 10(3) of Commission Implementing Regulation (EU) 2022/1173. This will 
allow the alignment of the quality assessment exercise with the scope of the area monitoring 
system. The main practical impact will be the reduction of the number of farm visits and the 
burden  for  farmers  in  the  context  of  the  quality  assessment  exercise.  However,  as  for  the 
information  referring  to  the  non-monitorable  eligibility  conditions,  it  will  be  based  on  the 
results  of  the  control  systems  implemented  by  the  Member  States. Therefore,  the  proposed 
amendments do not impact the original policy objectives. 

2.2. Amending Implementing Regulation (EU) 2022/1173 as regards the obligation to 
record  the  use  of  plant  protection  products  in  the  geo-spatial  aid  application 
(GSA)  

The amendment introduces the following changes: 

•  Deletion of the obligation that the GSA shall contain, where relevant, information 
on the use of plant protection products for parcels under interventions for sustainable 
and reduced use of pesticides under eco-schemes and environmental, climate-related 
and other management commitments9.  

Impact on national administrations 

9 Articles 31 and 70 of the Regulation (EU) 2021/2115, respectively 

4 

 
 
 
 
The  fact  that  the  registration  of  plant  protection  products  in  the  GSA  will  no  longer  be 
mandatory will provide Member States with greater flexibility to manage their own systems, 
ultimately leading to a reduction of costs since there will be no need to develop and maintain 
a dedicated Information and Technologies system to manage those registries. However, these 
cost reductions for national administration are not possible to quantify since it depends on the 
approach taken by each Member State. 

The proposed amendment does not preclude Member States from implementing that obligation 
where they consider it appropriate. It should be remembered that the requirement of record-
keeping of plant protection products is necessary as laid down in the Regulation concerning 
the placing of plant protection products on the market10. 

Impact on farmers 

The  deletion  of  the  obligation  to  record  the  use  of  plant  protection  products  in  the  GSA  is 
expected to reduce the burden for farmers regarding the time spent performing this task and 
allows more time to be spent on farm management or other tasks of the farmer’s choosing.  

As  mentioned  in  the  Commission  staff  working  document  SWD(2025)  236,  based  on  the 
results of the simplification study, farmers spend an average of 56 hours11 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).  

Taking into consideration the above, it can be estimated that there will be a reduction by 20%12 
of  the  overall  workload  for  farmers  for  recording  and  reporting  tasks  when  preparing  and 
submitting CAP aid applications due to the deletion of the obligation to record the use of plant 
protection products, that would correspond, on average, to 4 hours per concerned GSA.  In case 
of  use  of  external  advisory  services,  due  to  their  technical  expertise,  it  can  be  estimated  a 
reduction on average, of 2 hours per concerned GSA. 

In case of internal costs (administrative tasks performed by the beneficiary), each hour of work 
is estimated to correspond to EUR 11.2513. In case of the use of external advisory services, a 
sum of EUR 32.7014 per hour can be assumed as the cost incurred by a beneficiary for the tasks 

10 Article 67(1) of Regulation (EC) No 1107/2009 
11 According to ‘Study on simplification and administrative burden for farmers and other beneficiaries under the 
CAP’ farmers taking part in the European Commission targeted consultation on simplification of 2024 declared 
to spend an average of seven working days annually on administrative tasks 

12 Based on expert judgment 
13 According to ‘Study on simplification and administrative burden for farmers and other beneficiaries under the 
CAP’ farmers incur an estimated average annual cost of EUR 630 attributed to internal costs (e.g. working days 
spent  on  administrative  tasks)  (an  additional  amount  of  EUR 600  corresponds  to  external  advisory  services, 
totalling an estimated average annual cost of EUR 1 230 due to administrative burden arising from 2023-2027 
CAP for farmers and other CAP beneficiaries) 

14  Based  on  ‘Eurostat  Structure  of  earnings  survey,  Labour  Force  Survey  data  for  Non-Wage  Labour  Costs’ 

(update of 14.3.2025) 

5 

 
 
 
related  to  recording  and  reporting  plant  protection  products  under  the  preparation  and 
submission of a GSA.  

The  estimated  number  of  beneficiaries,  benefitting  from  the  deletion  of  the  requirement  to 
report information on the use of plant protection products for parcels under interventions for 
sustainable and reduced use of pesticides is around 3.5 million for financial year 2024 (claim 
year 2023). These include beneficiaries under eco-schemes (2.8 million) and environmental, 
climate-related  and  other  management  commitments  (730 000).  Taking  these  figures  into 
account  and  the  fact  that  78%15  of  EU  farmers  use  paid  external  support  for  aid-related 
administrative tasks, this results in estimated savings up to EUR 215 million annually for 
these farmers in all Member States. 

The objective of the amendment is to avoid reporting the same piece of data more than once 
and, therefore, does not impact the original policy objectives. 

2.3. Amending  Implementing  Regulation  (EU)  2022/128  as  regards  the  scrutiny  of 

transactions 

Scrutiny  of  transactions  under  the  CAP  refers  to  the  process  of  checking  the  validity  of 
transactions  through  financial  records  of  beneficiaries  (undertakings)  as  regards  market 
measures and sectoral interventions to ascertain whether transactions financed under the CAP 
have  actually  been  carried  out  and  have  been  correctly  executed.  Member  States  need  to 
appoint a special service in the administration that performs this task and has the right to access 
commercial documents and carry out checks in third countries as well. 

The amendment entails the following: 

•  Simplified  process  for  scrutiny  of  transactions  conducted  by  the  special  service 

appointed for scrutiny in the Member States.  

The  purpose  of  the  change  is  to  strike  the  right  balance  between  the  current  relevance  of 
scrutiny of transactions considering the substantial evolution of the management and control 
system of the CAP in the last 20 years and the resources that need to be deployed by Member 
States  for  this  specific  ex-post  control  annually  in  all  Member  States16.  The  simplification 
entails allowing Member States to select the sample of transactions based on a risk analysis 
rather than establish a sample based on a minimum coverage.  

Impacts of simplification concerning scrutiny of transactions 

Currently,  around  1 150  controls  are  carried  out  annually.  The  costs  of  controls  may  vary 
depending on whether it involves checking third country undertakings on the spot or not. For 
national administrations, the simplification is estimated to reduce by half the controls carried 
out, but the cost savings cannot be quantified. Depending on the type of the control, this can 

15  According  to  the  aforementioned  ‘Study  on  simplification  and  administrative  burden  for  farmers  and  other 

beneficiaries under the CAP’ 

16 selected on the basis of Article 46 (1)(2) and (3) of Implementing Regulation (EU) 2022/128 

6 

 
 
 
bring  benefits  to  CAP  beneficiaries  by  reducing  the  time  and  cost  entailed  in  attending  a 
control or providing additional information. 

The proposed  changes  do not  compromise the original  policy objectives, as  Member States 
should  have  an  efficient  management  and  control  system  in  place  as  per  Article  59  of 
Regulation  (EU)  2021/2116.  Furthermore,  following Annex  I  of  Regulation  (EU)  2022/127 
Member States should define the control system based on a risk analysis, which allows efficient 
use of resources in performing the necessary controls addressing the most relevant risks. This 
should in general cover the ex-spot controls as well, if considered necessary based on the risk 
analysis. 

Thus, in fact the proposed changes would align the requirements for scrutiny of transactions 
with the general conditions set out for the overall management and control system of a Member 
State. 

2.4. Amending  delegated  Regulation  (EU)  2022/126  as  regards  approval  of 
operational  programmes  of 
(associations  of)  producer 
transnational 
organisations, market withdrawals, rules on marketing standards, and minimum 
control rate for hemp cultivation 

The draft amendments to this act fall into two categories: 

•  Amendments that solely translate simplification changes to the underlying basic acts 
(CAP Strategic Plan Regulation 2021/2015 and Horizontal Regulation 2021/2016, the 
“Omnibus  III”  proposal).  These  amendments  do  not  entail  any  additional  cost 
reductions and are thus not included in this assessment. The effects of these changes 
have already been assessed in a staff working document accompanying the Omnibus 
III proposal17. 

•  Modifications that introduce additional simplification are listed and assessed in terms of 
reducing  administrative  burden  in  section  2  below.  Where  data  for  estimates  was 
available, the impacts were quantified, otherwise the document provides a qualitative 
appreciation of burden reduction18. The available figures are summarised in the annex. 

The amendment introduces the following changes: 

•  Specification  that  approval  of  the  operational  programmes  of  transnational 
(associations  of)  producer  organisations,  financed  under  the  CAP  sectoral 
interventions, takes place in the Member States where these organisations have their 
head offices.  

•  Removal of various prescriptive rules in relation to market withdrawals in sectoral 
interventions managed by producer organisations implementing approved operational 

17 SWD(2025) 236 final  
18 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. 

7 

 
 
 
programmes (e.g. fruit and vegetable sector) financed  under the sectoral CAP support 
for sectors, inclusion of the transport and conditioning costs in the calculation of the 
Union  compensation,  removal  of  the  condition  relating  to  the  share  of  market 
withdrawals, removal of obligations relating to documentation on the side of producers 
and recipients.  

•  Reduction of rules on marketing standards applying to withdrawn products 

•  Reduction  of  minimum  control  rate  for  hemp  cultivation  supported  under  CAP 
Plans, and more flexibility for the eligibility of hemp varieties newly registered. 

Impact  of  simplification  concerning  CAP  support  for  transnational  (associations  of) 
Producer Organisations 

Of more than 1 600 (associations of) producer organisations recognised in the EU, 45 - all in 
the fruit and vegetable sector - have members located in another/other Member State. Member 
State where the head offices of these transnational organisations are located are responsible for 
their  recognition  and  administrative  cooperation  with  other  Member  State(s),  including  on 
controls. The simplification clarifies responsibilities of the Member States where head offices 
are  located  by  establishing  that  they  are  also  responsible  for  approval  of  the  operational 
programmes of these organisations.  

For  producer  organisations,  the  change  reduces  the  uncertainty  as  regards  expenditure, 
administrative  management  and  controls  of  the  operational  programmes.  By  avoiding 
(potential) redundancies, it results in reduced paperwork linked to potentially multiple approval 
procedures  in  different  countries  and  multiple  controls  of  transnational  (associations  of) 
producer  organisations.  From  national  administrations’  perspective,  this  avoids  also 
redundant controls carried out by several Member States.  

Impact of simplification concerning CAP support when it comes to market withdrawals  

In case of market disturbance situations (e.g. oversupply), recognised producer organisations 
implementing  operational  programmes  may  take  the  decision  to  withdraw  part  of  their 
production from the market. There are two types of market withdrawals, for free distribution 
and  for  other  destinations  (e.g.  compost,  industry)  and  the  support  granted  to  those 
organisations is based on different calculation methods (e.g. depends on the market withdrawal 
type, on the products, transport and conditioning costs). The Union financial assistance of 50% 
of  the  actual  expenditure  incurred  is  increased  to  100%  for  market  withdrawals  for  free 
distribution of fruit and vegetables provided the withdrawn volume does not exceed 5% of the 
volume marketed by the producer organisation. In all other cases, the Union financial assistance 
is  limited  to  50%.  The  market  withdrawals  in  the  fruit  and  vegetables  sector  amounted  to 
EUR 28.3 million for both free distribution and other destinations. This represents less than 1% 
of the total expenditure eligible for support in this sector.  

This  simplification  provides  the  following:  a  simplified  calculation  method  to  compensate 
production  costs  by  organisations  implementing  market  withdrawals,  and  a  reduction  of 
administrative tasks for both producer organisations and managing authorities. 

8 

 
 
For producer organisations, the removal of this obligation results in: 

• 

lower  administrative  burden  stemming  from:  (i)  not  being  subject  anymore  to  the 
presentation of supporting documents, not limited to a certain type of packages, (ii) no 
more requirements on the recipients, (iii) simpler marketing standards to be complied 
with. 

•  a simplified financial support, by (i)  removing the Union conditioning costs; the costs 
being calculated by Member States as transport costs; (ii) including the transport and 
conditioning costs in the maximum Union compensation and increasing fixing at 90% 
the  percentage  for  compensation  (since  conditioning  costs  are  now  including  in  the 
amount of compensation), and (iii) removing the limit of 10% of volume withdrawn 
(not foreseen in the basic act).. 

For national administrations, besides eliminating administrative costs linked to maintaining 
records or checking documentation, standardisation of the calculation methods for the support 
will help increase the efficiency and consistency in managing the support. 

Impact of simplification concerning the minimum control rate for hemp 

CAP  support  can  be  granted  also  when  farmers  cultivate  hemp,  provided  the  varieties  used 
have a tetrahydrocannabinol (THC) content not exceeding 0.3%. Therefore, the farmers have 
to use certified seeds of hemp varieties which are listed in the Common Catalogue of Varieties 
of Agricultural Plant Species19. The THC content of those varieties has to be verified and should 
not exceed for two consecutive years the limit of 0.3%, which is a legal requirement set in the 
basic act.  

The current legislation establishes a minimum, 30% control rate in relation to cultivated area 
under CAP support (or 20% in case the cultivation in question received a prior authorisation). 
The main aim of these controls is not to detect illegal cultivations given that the farmer declares 
the areas and provides the seeds label to the control authorities, but to verify the stability of the 
THC content in a given variety in different territories of the same Member State and in relation 
to changing climate conditions. Notably, during COVID, the rate was reduced to 10% without 
significant impacts on the correctness of the results. Moreover, from 2023 the maximum THC 
limit was raised from 0.2% to 0.3%, therefore the risk of exceeding the limit is very low for 
the majority of varieties which proved to be traditionally below the 0.2%. The risk remains 
with the new varieties with an average THC content comprised between 0.2 and 0.3%.   

The simplification entails reduction of control rate from 30% to 15% (or from 20% to 10%) of 
the area declared.  

Assuming, based on the trend of cultivation data, about 40 000 ha, the number of hectares to 
be controlled will be reduced by 5 000 hectares (from approximately 10 000), halving not only 

19https://food.ec.europa.eu/plants/plant-reproductive-material/plant-variety-catalogues-databases-information-
systems_en 

9 

 
 
 
the number of field  visits and samples taken, but  also  the number of laboratory analyses to 
determine the THC. Based on the figures of one Member State relating a ratio of on-the-spot 
controls to area (one control covering 7 ha on average), and extrapolating this data to all areas 
under cultivation, one arrives at 1 406 total controls. Reducing by half the number of controls 
would result in the reduction of 700 controls and associated laboratory analysis, annually.  

Eliminating  partially  the  controls,  leads  to  reduction  of  enforcement  costs  on  the  side  of 
national  administrations  linked to  preparing on-site-visits,  attending  them, taking samples 
and performing the analysis. Assuming that each control and analysis takes one day for two 
persons involved in sampling and analysis, the cost reduction is approximately EUR 366 240 
annually, using average EU values for labour costs (EUR 32.7 per hour).  

For farmers,  this reduces the time spent  on preparing, attending  and following up a single 
control  and  half  a  day  spent  on  each  by  a  farmer,  translates  into  an  annual  reduction  of 
administrative costs in the range of EUR 31 500 to 92 000 (700 x 4 h x 11.25 or 32.7), using 
data for labour costs from the Simplification study and average EU values for labour costs.  

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

Measures* 

Farmers 
(annual savings) 

National 
administrations 
(annual savings) 

€ 3.85 million 

Liming the scope of AMS and GSA 
quality assessment to monitorable 
conditions 
Deletion of obligation to record use 
of plant protection products in GSA 
Reduction of minimum control rate 
relating to hemp 

€ 215 million 

€ 31 500 - 92 000 

€ 366 000 

* Measures leading to additional savings for which quantification is not possible are not 
presented in this table 

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