REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the operation of the new delivery model by the Member States and contribution of Member States’ CAP Strategic Plans to achieving environmental and climate-related commitments of the Union
Date: 2026-01-26
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: EAFRD, EAGF, EU Member State, aid to agriculture, climate change policy, common agricultural policy, management planning, performance audit, rural development, sustainable agriculture

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.1.2026  COM(2026) 37 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL         on the operation of the new delivery model by the Member States and contribution of Member States’ CAP Strategic Plans to achieving environmental and climate-related commitments of the Union     {SWD(2026) 19 final}  
 
 
INTRODUCTION 

Since its introduction, the  common  agricultural  policy (CAP) has  evolved significantly, 
addressing emerging needs and adjusting its modalities. The new delivery model for the 
CAP  2023-2027  shifted  emphasis  from  compliance  with  detailed  EU  rules  to  a 
performance-based policy driven by objectives. The aim is to achieve tangible results 
and deliver on the common objectives, while giving Member States more flexibility in 
deciding on the details of the policy.  

Central  to  this  model  is  (i)  a  single  planning  tool  –  a  CAP  strategic  plan  for  each 
Member State1 – integrating for the first time instruments of both CAP funds into 
common  intervention  strategies;  (ii)  greater  stakeholder  participation;  and  (iii)  a 
focus on performance, with the establishment of a common performance framework and 
the performance review process. This approach was introduced to improve the coherence 
and increase the effectiveness of CAP interventions, while better addressing specific and 
diverse  national  needs  in  contributing  to  the  achievement  of  the  common  EU  CAP 
objectives. The new delivery model also entails a new approach to assurance where audits 
focus on the design and functioning of the Member States’ governance systems instead of 
auditing individual beneficiaries. 

This delivery model has already been subject to several adjustments and simplifications 
based  on  stakeholders’  feedback  and  Member  States’  requests  after  two  years  of 
implementation. The insights from its implementation have also guided the proposal for 
the future period 2028-2034. 

This  report  responds  to  the  co-legislators’  request  (Article  141(3)  of  Regulation  (EU) 
2021/2115 of the European Parliament and of the Council2) to present information on the 
operation  of  the  new  delivery  model  and  a  first  assessment  of  the  contribution  of 
interventions  planned  in  the  28  CAP  strategic  plans  to  the  achievement  of  the  EU’s 
environmental and climate objectives.  

I.  OPERATION OF THE NEW DELIVERY MODEL BY THE MEMBER STATES  

A.  Strategic and more evidence-based design of CAP plans 

The Commission made a proposal for a reformed CAP in 2018 in line with the 2021-2027 
Multiannual Financial Framework. Following negotiations between the EU co-legislators, 
the CAP regulations were only adopted in 2021, to be operational from 1 January 2023.  

To help Member States prepare and design their CAP plans, the Commission launched a 
structured dialogue in 2020, with exchanges on the status of agriculture and rural areas in 
each Member State, and published specific recommendations in December 20203.  

1 Except for Belgium. 
2  Regulation  (EU) 2021/2115  of  the  European  Parliament  and  of  the  Council  of  2 December  2021 
establishing  rules  on  support  for  strategic  plans  to  be  drawn  up  by  Member States  under  the  common 
agricultural  policy  (CAP  Strategic  Plans)  and  financed  by  the  European  Agricultural  Guarantee  Fund 
(EAGF) and by the European Agricultural Fund for Rural Development (EAFRD) and repealing Regulations 
(EU) 
6.12.2021, 
ELI:  http://data.europa.eu/eli/reg/2021/2115/oj).  
3 Communication from the Commission to the European Parliament, the Council, the European Economic 
and Social Committee and the Committee of the Regions Recommendations to the Member States as regards 
their strategic plan for the Common Agricultural Policy, COM/2020/846 final. 

No 1307/2013 

No 1305/2013 

(EU) 

435, 

and 

(OJ 

L 

1 

 
 
 
To  design  their  interventions,  Member  States  were  required  to  produce  a  thorough 
assessment of needs, based on an analysis of the strengths, weaknesses, opportunities and 
threats (SWOT) of their territory and agri-food sector, and to develop a precise intervention 
logic. The assessment was required to be exhaustive, by assessing whether needs would be 
addressed through the CAP plans or other EU or national tools considered a better fit for 
the purpose.  

The plans were approved by the Commission in the second half of 2022 following the 
formal  replies  to  the  observation  letters  from  the  Commission  in  response  to  each  plan 
submitted.  

1-  New governance  

Strategic planning has led to reorganisations and new working methods in Member 
States’  administrations.  A  single  plan  covering  all  interventions  required  greater 
collaboration between departments in charge of direct payments, rural development and 
sectoral  support,  but  also  greater  coordination  between  regional  and  national 
ministries/departments.  Member  States  with  strong  collaborative  working  practices 
between administrations, with clearly established responsibilities and efficient channels of 
exchange  were  able  to  adapt  more  quickly  to  this  new  delivery  model.  However,  some 
Members States with a specific division of national and regional competences encountered 
some difficulties. 

Dynamics  vary  widely  across  Member  States,  but  the  new  delivery  model  has  brought 
about  better  governance  of  the  CAP  with  explicit  legal  provisions  on  the  role  of 
partnership. The required involvement of stakeholders in designing and implementing the 
plans  has  led  to  a  better  alignment  to  Member  States’  needs.  However,  while 
regional/territorial input was possible in the plans, some regions felt they had less say in 
the design of the plans and experienced some input delays due to national coordination. 
The length of the plans (often several thousand pages) was also identified as an issue by 
several managing authorities and stakeholders.  

2-  Design based on a needs assessment and different planning choices 

To design their plans, Member States used SWOT analysis, partnership consultations, the 
Commission’s recommendations and observation letters. They highlighted that while the 
analysis and identification of needs took place under good conditions, the late adoption of 
EU  legislation  reduced  the  time  dedicated  to  finetuning  the  design  and  planning  of 
interventions and to innovate. Anticipation at national level was crucial at this stage. 

The plans were largely used to address socio-economic, environmental and climate-related 
needs.  For  the  period  2023-2027,  8%  of  the  CAP  allocation  was  planned  for  rural 
development  besides  agriculture.  For  renewable  energy,  innovation,  digitalisation,  risk 
management  knowledge  sharing  and,  to  a  certain  extent,  rural  policy  measures,  some 
Member  States  planned  to  achieve  their  objectives  as  well  with  other  EU  or  national 
funding, requiring closer coordination and revealed potential for more synergies.  

Good  planning  is  the  corner  stone  of  a  performance-based  model,  but  it  proved 
difficult. Planning annual outputs, unit amounts and result indicators (targets) for financial 
years  2023  to  2027  required  relevant  data,  good  evidence  from  stakeholders  and 
experienced  staff.  Member  States  have  adopted  different  strategies,  with  some 
programming on a high granular level (e.g., numerous unit amounts and outputs set at the 
2 

 
level of each sub-intervention), while others opted for less granularity (e.g., at the level of 
each  intervention).  For  example,  1 913  interventions  and  10 754  sub-interventions  are 
planned in the 28 CAP plans. The most diversified types of intervention are environmental 
and  climate  interventions  (5 282  sub-interventions)  under  rural  development  and 
investments (2 172).  

3-  Assessing the plans required a comprehensive approach   

The  Commission’s  assessment  considered  whether  the  plans  submitted  were  consistent 
with the requirements of EU legislation and contributed to the achievement of 10 specific 
CAP objectives. Attention was paid to the contribution of the planned intervention strategy 
to  achieving  environmental  and  climate-related  objectives,  including  certain  EU  Green 
Deal  targets,  and  their  coherence  with,  and  contribution  to,  the  EU  environmental  and 
climate legislation4, with no backsliding compared to the 2014-2022 period5.  

The CAP’s ambition is reflected in the targets set at result indicator level which are to be 
reached through the supported interventions. It is also reflected in the detailed requirements 
and eligibility conditions of those interventions. To support the objective assessment of the 
plans, from an environmental and climate-related perspective, a matrix developed by the 
Joint  Research  Centre  provided  evidence  on  the  link  between  farming  practices  and 
objectives6.  

The objective assessment of the adequacy of the intervention strategy and target levels of 
each plan in view of the national needs and objectives identified by the Member State was 
a complex process, notably due to (i) different situations and priorities in Member States; 
(ii) different levels of planning; (iii) complex links between interventions and targets; (iv) 
targets  expressed  in  a  different  unit  to  objectives  (e.g.,  share  of  area  versus  change  in 
CO2eq.);  and  (v)  national  legislation  or  tools  other  than  the  CAP  contributing  to  the 
achievement of the same objectives.  

B.  Implementation of plans is on track 

After  the  Union  secondary  legislation  was  adopted  at  the  end  of  2022,  Member  States 
completed  their  national  CAP  implementation  framework  (legislation,  application 
processes,  IT  systems).  Administrations  had  a  considerable  workload,  especially  as 
implementation of the 2014-2022 rural development programmes is continuing in parallel 
for three more years (until the end of 2025). In practice, this has led to capacity issues and 
high time pressure on the development of IT tools, the preparation of calls for projects and, 
sometimes,  delays  and  late  communication  with  beneficiaries,  affecting  uptake  and 
perception by farmers. 

Annual performance reports, the main reporting tool of the new delivery model, have two 
parts: one, qualitative, presents the progress made in implementing plans, while the other, 
quantitative,  provides  performance  indicators  and  justifications  for  deviations  from  the 
milestone values of results indicators.  

Due to the timeline of the implementation of the interventions, the performance report for 
financial year 2024 submitted in February 2025 was the first report containing data on all 

4 Listed in Annex XIII to Regulation (EU) 2021/2115. 
5 Article 105 of Regulation (EU) 2021/2155. 
6 See references 1, 2 and 9 in the accompanying Staff Working Document. References, as well as additional 
data, can be found in the Staff Working Document accompanying this report.  

3 

 
 
result indicators and most interventions planned. Under the new delivery model, Member 
States planned annual outputs and results related to income support, rural development and 
sectoral interventions for the first time. 

1-  Good planning of area-based interventions 

The  comparison  of  planning  and  realisation  makes  it  possible  to  assess  progress  in 
implementing the plans and the difficulties faced.  

-  Basic income support is the intervention with farmers’ uptake closest to planning at EU 

level (100%) but also in each plan.  

-  The uptake of redistributive income support corresponds to 98% of the planned EU 

value, with some variations among plans.  

-  However, coupled income support and the top-up for young farmers have been more 

difficult to plan.  

-  As  a  newly  introduced  instrument,  the  uptake  of  eco-schemes  has  generally  been 
underestimated, as they cover 10% more area than planned at EU level, with significant 
variations among plans. 

At EU level, the uptake of rural development area-based support has reached between 87% 
and 91% of the planned area. Investment, installation support, and training or cooperation 
projects are usually slow to start in the early years of the programming period, especially 
if new interventions overlap with similar measures from the previous programming period. 
Overall, expenditure in these areas was lower than anticipated, except for non-productive 
on-farm investments.  

2-  Difficulties of planning intervention unit amounts  

Member  States  can  adjust  the  payment  to  the  beneficiary  based  on  the  uptake  of  an 
intervention (within a range), given the difficulty of anticipating the uptake and the need 
to  better  manage  financial  envelopes.  Only  half  of  eco-schemes  were  paid  at  the  unit 
reference amount (± 10%). Coupled support was generally more rewarded than planned, 
with a lower uptake than anticipated. Fine-tuning investment aid was difficult as only 23% 
of the sub-interventions were paid at the average reference amount (± 10%). The observed 
discrepancies were mostly due to changes in the economic and geopolitical context since 
the preparation of plans or low accuracy of uptake estimations. 

3-  Discontinuation of performance clearance 

The objective of the annual performance clearance exercise was to check that all declared 
expenditure  had  a  corresponding  output.  This  was  verified  by  comparing  for  each 
intervention the realised unit amount calculated based on the annual performance report 
with the (maximum) planned unit amount in the plan. After two years of implementation, 
it  became  evident  that  the  administrative  burden  of  the  annual  performance  clearance 
exercise, particularly the need to justify each unit amount deviation, was not proportionate 
to the additional assurance on CAP expenditure provided. Its discontinuation was therefore 

4 

 
proposed in the 2025 CAP simplification package7, without affecting the Union’s ability 
to ensure effective budgetary supervision and assurance.  

4-  Some deviations from milestones due to the start of the implementation but 

no corrective actions required yet 

Based  on  the  2024  performance  report,  in  2025  the  Commission  carried  out  the  first 
biennial performance review8, taking into consideration a selection of 22 result indicators. 
All  performance  reports  showed  deviations  above  35%  for  one  or  more  result 
indicators. These were mostly linked to rural development interventions: knowledge and 
innovation,  investments  in  farm  modernisation,  better  supply  chain  organisation  and 
afforested land. Member States’ justifications mainly related to delays in setting up the new 
framework  and  to  the  use  of  the  remaining  financial  envelopes  of  the  2014-2022  rural 
development programmes financing similar measures. According to Member States, most 
of these difficulties will be addressed in the medium term and should not have an impact 
on the final targets. 

The  deviations  were  discussed  with  each  Member  State  during  their  individual  annual 
review meeting. As the justifications presented and the remedial actions envisaged seemed 
sufficient  to  address  them,  no  action  plan  was  requested  by  the  Commission.  It  can  be 
expected that the delays, and the resulting gaps between the actual and the planned values, 
can be recovered in the coming years. The situation will be reviewed again in the 2025 
performance reports. 

5-  Adaptation of the planned financial envelopes to actual uptake 

Member States have the possibility to reallocate unspent amounts from one intervention to 
another  intervention  under  certain  conditions.  In  financial  year  2024,  they  used  this 
possibility  particularly  for  direct  payments.  The  eco-scheme  was  a  novelty,  and  some 
Member States had difficulties spending their planned amounts. On top of this, the eco-
scheme  is  a  ring-fenced  budgeted  intervention  and  the  margin  for  offsetting  amounts 
against 
that  had 
underperformed were reviewed or better advertised to potential beneficiaries. The current 
state  of  expenditure  for  2025  shows  a  much-improved  situation  with  marked  over-
execution  for  eco-schemes.  The  redistributive  payment  and  the  complement  for  young 
farmers became the destination for some of the unspent amounts. Basic income support 
was well executed compared to the previous programming period.  

interventions  remained 

limited.  Eco-schemes 

those  for  other 

6-  CAP plans are living documents 

Amendments of plans are a necessary feature of any programming process, as they provide 
the  flexibility  needed  to  address  difficulties  encountered  on  the  ground  and  emerging 
needs.  

7  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. 
8  Every  two  years  the  Commission  verifies  that  the  planned  targets  values  (milestones)  are  going  in  the 
direction of the planned values of result indicators. A deviation of more than 35% in the first year, and of 
25%  later  on,  should  be  justified.  Corrective  actions  might  be  requested  by  the  Commission  if  the 
justifications provided are not convincing enough. 

5 

 
 
Up to September 2025, 93 amendments  had been requested by Member States. All 
plans were amended between 2 and 5 times from their approval to September 2025. 
Changes reflect changing economic circumstances, the need to make interventions more 
attractive, or to  simplify. Through amendments,  34% of the targets  were changed, with 
significant  variations  among  plans.  The  targets  most  often  increased  concern  social 
objectives because of the need to align them with the LEADER9 strategies in question after 
the approval of plans. Overall, the modifications were balanced between target increases 
and  target  decreases,  including  for  green  architecture  targets.  In  its  assessment  of  the 
amendments,  the  Commission  ensured  consistency,  as  well  as  maintenance  of  a  level 
playing field, while considering specific national challenges. 

In 2025, the Commission proposed to further simplify the process of amending the plans 
by limiting formal amendment requests to strategic changes only, which  would make it 
possible for the plans to be amended more quickly. The proposal referred to as Omnibus 
3 10 has been adopted and will apply in 2026. 

7-  A new assurance model and single audit principle  

Under  the  new  delivery  model,  assurance  is  based  on  the  proper  functioning  of 
Member States’ governance systems. The eligibility of expenditure is ensured by the 
paying agencies and verified annually by the certification bodies. Certification bodies 
provide opinions on the annual accounts, on the effectiveness of the governance systems, 
and  on  the  reliability  of  performance  reporting.  The  Commission  conducts  risk-based 
audits primarily of their work and, only when it is not satisfactory, of the paying agencies 
themselves. 

The  reinforcement  of  the  single  audit  principle  is  a  key  feature  of  the  reform. While  it 
increases  efficiency,  strengthens accountability  at national  level  and avoids overlapping 
controls,  it  also  makes  the  assurance  more  dependent  on  timely  and  reliable  work  of 
certification bodies. The Commission maintains regular contacts with paying agencies and 
certification  bodies  to  ensure  a  common  understanding  and  the  consistent  fulfilment  of 
assurance requirements. If the Commission detects serious deficiencies in the governance 
systems, conformity procedures are launched and, if the deficiencies are confirmed, lead 
to financial corrections.  

Between 1 January 2024 and 30 September 2025, the Commission carried out 78 audits of 
governance systems as a whole or of selected CAP interventions. In some cases, potential 
serious deficiencies were identified, and conformity procedures were launched to assess 
possible risks to  the  EU  budget. As these take time, no conformity  procedure  had been 
finalised by the end of September 2025. 

8-  A new preventive approach with the area monitoring system 

Under the new delivery model, the responsibility for designing and implementing controls 
in the integrated administration and control system was largely shifted to Member States. 

9 LEADER: Links between activities or actions for the development of the rural economy 
10 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). 

6 

 
 
The  introduction  of  the  area  monitoring  system  obliges  them  to  monitor  by  satellite 
imagery the fulfilment of eligibility conditions by farmers, when technically possible. Such 
monitoring  replaces  on-the-spot  controls,  thereby  greatly  alleviating  the  administrative 
burden. The preventive approach of the area monitoring system also makes it possible for 
farmers to correct their CAP applications without being penalised. In claim year 2023, this 
resulted  in  corrections  for  3.3  million  of  hectares  (2%  of  EU  utilised  agricultural  area, 
UAA), helping to reduce penalties and alleviate the administrative burden for farmers and 
administrations. 

However, the Member States and farmers could reap even more benefits from the use of 
the  area  monitoring  system  by  making  more  interventions  and  eligibility  conditions 
monitorable in the plans in order to support this preventive approach.  

C.  Better and comprehensive performance monitoring  

The performance framework makes it possible to monitor progress in implementation and 
paves the way for a process of continuous improvement.  

The framework integrates reporting on direct payments, rural development, and sectoral 
interventions into the same set of result indicators, according to their purpose. It establishes 
an  exhaustive  list  of  performance  indicators.  Each  intervention  is  linked  to  one  output 
indicator  and  to  all  relevant  result  indicators11,  to  ensure  a  comprehensive  depiction  of 
CAP contributions.  

The  integration  of  reporting  for  both  policy  monitoring  and  assurance  in  the  annual 
performance report has streamlined processes and increased consistency. However, it has 
also led to more complex calculation rules (partial outputs) and difficult aggregations (the 
proliferation of units of measurement). Managing authorities had trouble meeting the 15 
February deadline for the annual performance report and providing all the certified data 
and  necessary  justifications,  while  for  the  purpose  of  monitoring,  data  availability  was 
delayed. 

The current result indicators are based mostly on action coverage because it is difficult to 
measure direct policy outcomes. However, the Commission has developed rough estimates 
for  climate  mitigation  and  soil  organic  content  to  be  able  to  propose  result  indicators 
measuring outcomes for 2028-2034. 

Member States need to evaluate the contribution of their plans to the achievement of all 
objectives  during  the  programming  period  and  have  more  freedom  to  design  their 
evaluation plans. Supported by the Commission and the EU CAP Network, most of them 
have drawn up ambitious evaluation plans.  

D.  A major simplification effort 

Experience  with  the  implementation  of  the  plans  has  highlighted  the  need  for  targeted 
adjustments of certain aspects of the CAP framework to alleviate the administrative burden 
for  farmers  and  administrations.  To  this  end,  two  packages  of  legislative  and  non-
legislative  actions  were  produced  in  2024  and  2025  to  increase  the  flexibility, 
proportionality, and clarity of CAP-related rules (such as those on force majeure). 

11 Interventions must be linked to all result indicators to which they contribute directly and significantly. 

7 

 
 
 
On the one hand, several changes increase flexibility in the way farmers manage land under 
CAP  support  instruments  and  to  better  align  with  on-farm  realities  (adjustments  to 
conditionality rules). On the other hand, some changes streamline the implementation of 
the CAP plans for national authorities (amendments, the discontinuation of performance 
clearance).  

The Commission also published a roadmap of further simplification actions to be taken 
throughout 2025, outlining planned actions, tools, and an indicative timeline for further 
improvements of CAP secondary legislation.  

II.  CONTRIBUTION OF THE CAP STRATEGIC PLANS TO ACHIEVING THE EU’S 

ENVIRONMENTAL AND CLIMATE-RELATED COMMITMENTS  

The environmental and climate-related objectives of the CAP are tackling climate change, 
protecting natural resources, and enhancing biodiversity. The 2023-2027 CAP introduced 
a policy mix of interventions, conditionality, and a ring-fenced budget (the CAP’s green 
architecture) to achieve these objectives. Member States drew up environmental strategies 
to  contribute  to  EU legislative acts  on  the environment and  climate,  and help  reach  the 
EU’s Green Deal targets, and to fulfil the obligation12 to make a greater overall contribution 
to the achievement of those specific objectives compared to the period 2014-2022. 

Each Member State chose its own policy mix to design its green architecture. The area-
based interventions are supplemented by support  for green investments, cooperation, or 
training projects. The current  CAP continues to  support  management  commitments  and 
investment, well known by farmers and adapted to their needs. On good agricultural and 
environmental conditions  (GAEC), some adjustments were introduced in 2024 to  make 
implementation more adapted to the realities of farming: targeted exemptions, temporary 
derogations, and the obligation to reward the maintenance and creation of non-productive 
areas. 

New  in  2023,  eco-schemes  make  it  possible  to  scale  up  agro-environmental  actions 
with a dedicated large budget and annual commitments. Some Member States focused on 
getting  many  farmers  involved  in  a  small  and  incremental,  but  widespread,  change  in 
farming practices, while others designed more targeted interventions. All Member States 
had to strike the right balance between the level of the premium and ambition to ensure the 
attractiveness of the scheme. In most plans, the eco-scheme was more subscribed to than 
anticipated, while in a few other changes were necessary to adapt interventions and support 
their uptake by farmers. At EU level, 47% of farmers received eco-scheme support in 
financial year 2024, for 58% of UAA. 

After  two  years  of  implementation,  it  is  too  early  to  measure  the  real  impacts  of  the 
interventions on the achievement of the environmental and climate-related objectives in 
the  CAP  plans.  In  many  cases,  impacts  can  be  measured  only  after  several  years  (e.g., 
biodiversity regeneration, air and water pollution, soil health, etc.) However, three recent 
studies help estimate and quantify the potential contributions of the planned interventions 
to the achievement of these objectives. The studies assessed each CAP intervention based 
on (i) the farming practices (or requirements) supported, (ii) the planned coverage, and (iii) 
the impact of each farming practice on climate, biodiversity, clean air and soil health.  

12 Article 105 of Regulation (EU) 2021/2115. 

8 

 
 
The study on ‘Budget tracking of the CAP contribution to climate change, biodiversity and 
clean air action’13 shows that 33% of the CAP budget makes a positive contribution to 
climate, 39% to biodiversity and 20%  to clean  air. In addition, the study  shows that 
several  interventions  contribute  and  not  only  those  belonging  to  the  green  architecture 
interventions. This approach considers the definitions of interventions and the targeting of 
support14, and results in a slightly lower, yet comparable, contribution to climate than when 
using Rio markers15. This proves the relevance of the Rio markers, a simplified approach 
which  is  needed  at  planning  phase.  These  budget  tracking  methodologies  only  assess 
positive impacts, this should be kept in mind when interpretating the results, which should 
be complemented by ex-post evaluations. 

The  CAP  plans  represent  a  significant  potential  contribution  to  reaching  the  2030 
climate  mitigation  targets.  The  study  on  ‘Rough  estimate  of  the  climate  change 
mitigation  potential  of  the  plans’16  indicates  a  potential  positive  contribution  of  the  28 
plans to greenhouse gas emission reductions and enhanced removals of 35 million tonnes 
of CO2 equivalent per year on average over the period 2023-2027, distributed between 5 
million tonnes of non-CO2 emission reduction and 30 million tonnes of carbon removals 
per year. This estimation comes with uncertainties, in particular, the extent to which the 
annual  positive  contribution  can  be  cumulated  until  2027  strongly  depends  on  the 
additionality of the actual uptake of practices by farmers throughout the period. 

Member  States  have  developed  a  wide  range  of interventions  to  improve  soil  health 
that contribute to the achievement of all three specific objectives. The study ‘Rough 
estimate of the soil protection potential of the CAP’17 examines the implementation choices 
of 13 plans representing EU pedoclimatic diversity where soil protection is identified as a 
priority.  It  assesses  six  soil  characteristics.  For  example,  the  potential  increase  in 
agricultural  soil  organic  carbon  content  is  estimated  at  0.92%  per  year  for  CAP 
interventions  and  at  0.14%  per  year  for  GAEC  requirements.  Crop  rotation  and 
diversification account for most of the estimated potential increase in soil organic content. 
This is a preliminary outcome, still ‘rough’ due to some limitations, mainly the difficulty 
of  accounting  for  the  local  context,  and  it  doesn’t  cover  all  aspects  of  soil  health  (e.g. 
salinization, subsoil compaction...). 

The studies mentioned above estimate CAP contributions based on the planned actions, so 
they cannot prejudge the final outcomes. However, the implementation of the plans shows 
that on EU average most environmental and climate-related annual milestones were 
surpassed in 202418. In particular, interventions to improve and protect soil cover 51% of 
EU UAA and actions to enhance carbon storage in soil and biomass cover 35% of UAA, 
which augurs well for the future. 

On the EU Green Deal targets, some positive trends can be observed even if it is too 
early to assess the contribution of the CAP. 

13 See reference 3 and table 4 in accompanying Staff Working Document. 
14 The tracking methodology applied in the study is significantly more scientific-based and more granular 
than the current climate tracking methodology and therefore is expected to yield more precise results. 
15 Rio Markers are qualitative indicators developed by the OECD to help donor countries and development 
agencies  track  how  much  development  aid  supports  environmental  goals  under  the objectives  of  the  Rio 
Conventions, such as biodiversity, desertification, and climate change (mitigation & adaptation).  
16 See reference 4 in accompanying Staff Working Document. 
17 See reference 5 in accompanying Staff Working Document. 
18 See reference 8 in accompanying Staff Working Document. 

9 

 
 
In 2023, 11% of UAA was farmed organically, 6% of UAA was supported with specific 
area-based  organic  support.  However,  some  Member  States  said  they  had  difficulties 
reaching their target for organically farmed land due to lower demand than expected for 
organic products and rising costs. They planned remedial actions, but the target of 25% of 
farmland’s being organic can only be reached with a strong increase also on the demand 
side for organic products. 

The  EU  Green  Deal  target  of  a  50%  reduction  in  nutrient  losses,  while  ensuring  no 
deterioration in soil fertility, is linked to a reduction in the use of fertilisers by at least 20% 
by  2030  compared  to  the  2012-2014  average. Almost  all  plans  support  more  balanced 
fertilisation  and  better  practices,  for  example  by  banning  synthetic  fertilisers  or  their 
substitution with organic fertilisers, precision farming, and other practices to limit air and 
water  nutrient  losses.  Sustainable  nutrient  management  practices  were  implemented  on 
14%  of  EU  UAA  in  financial  year  2024.  On  average  between  2021  and  2023,  farmers 
across the EU used 8.9 million tonnes of nitrogen fertilisers, 9% less than between 2012 
and  2014  (reference  period).  Since  the  recent  decline  is  partly  due  to  the  high  cost  of 
synthetic nitrogen fertilisers, subsequent to the ongoing war in Ukraine, it is too early to 
assess its impact in terms of reaching this ambitious target. 

The EU Green Deal target for antimicrobials is to achieve a 50% reduction in sales for 
farmed  animals  and  aquaculture  by  2030,  compared  to  2018  levels.  The  European 
Medicines Agency (EMA) announced a drop of 25% in overall sales of antimicrobials for 
use in food-producing animals in the EU between 2018 and 202319, bringing the EU closer 
to reaching the 2030 reduction target.  

A lot has been done to make the use of pesticides more sustainable and to reduce their use, 
with relevant practices covering 29% of EU UAA in financial year 2024, mainly through 
agri-environment-climate  commitments  and  support  for  organic  farming.  Crop  rotation 
and buffer strips play an important role in the reduction of the use of pesticides. However, 
it is too early to judge the extent to which CAP interventions contribute to reaching the EU 
Green Deal targets (50% reduction in the overall use and risk of chemical pesticides, and 
in the use of most hazardous pesticides compared to 2015-2017). 

At EU level, landscape features covered 5.6% of agricultural land in 202220 and fallow 
land 3.6 % in 2020, so both will contribute to reaching the target of 10% of agricultural 
area as high diversity landscape features. The interventions supporting landscape features 
in  the  CAP  plans  are  generally  broader  and  aim  to  enhance  biodiversity,  habitats  and 
species  through  greater  structural  diversity.  The  relevant  annual  milestone  has  been 
reached in most plans, with 1.5% of EU UAA covered by support for managing landscape 
features in financial year 2024. From 2025, due to the costs for farmers of fulfilling it, the 
obligation to keep a minimum share of arable area for landscape features and fallow under 
GAEC 8 has been replaced by the obligation for Member States to propose an equivalent 
eco-scheme supporting the maintenance and establishment of new landscape features. 

19 See reference 6 in accompanying Staff Working Document 
20 See reference 7 in accompanying Staff Working Document 

10 

 
 
 
 
CONCLUSION  

The novelty of the new delivery model lies in its integrating instruments more strategically, 
the greater flexibility it affords Member States to adapt the design of interventions to their 
needs.  Strategic  programming  based  on  needs  assessment  was  welcomed  by  Member 
States  and  beneficiaries  and  the  new  delivery  model  has  had  a  positive  impact  on  the 
governance  of  the  CAP  (partnership,  use  of  evidence).  The  introduction  of  the  area 
monitoring system also provides opportunities to alleviate the administrative burden for 
farmers and administrations.  

However,  the  late  adoption  of  the  Union  legal  framework  did  complicate  matters  for 
Member States, and they have pointed out the importance of receiving information in time 
to  enable  an  integrated  and  coordinated  approach  of  the  CAP  toolbox  and  avoid  gold 
plating. Not all flexibilities were used, including for Member States to simplify rules, to 
avoid the risk of financial corrections.  

Unnecessary complexities were also addressed by two simplification proposals tabled by 
the  Commission  in  March  2024  and  May  2025,  making  notably  provision  for  (i)  the 
replacement  of  the  obligation  to  keep  a  minimum  share  of  arable  area  for  landscape 
features and fallow  by an equivalent  and  voluntary eco-scheme for farmers and (ii) the 
discontinuation of the annual performance clearance exercise.   

Experience has shown that Member States managed to correct or adapt the plans by means 
of  amendments.  To  facilitate  further  amendments,  a  notification  procedure  for  non-
strategic  amendments  has  been  introduced. An  appropriate  balance  needs  to  be  struck 
between simplifying planning and reporting and the level of information needed to assess 
compliance with EU law and the contribution of the plans to the CAP’s specific objectives, 
and  between  the  adaptability  of  plans  and  both  a  focus  on  performance  throughout  the 
programming period and providing certainty to farmers. 

Following  the  first  biannual  performance  review,  the  Commission  concluded  that  the 
implementation of the plans was on track, with deviations remaining within the boundaries 
set  by Article  135  of  Regulation  (EU)  2021/2115.  None  of  the  plans  require  corrective 
actions.  

The analysis confirms that the plans have the potential to contribute to the achievement of 
the environmental and climate-related objectives of the CAP. CAP plans’ implementation 
shows that on EU average most environmental and climate-related annual result indicator 
milestones  were  surpassed  in  2024.  However,  the  quantification  of  the  CAP  plans’ 
contribution to reaching environmental and climate objectives requires a longer period of 
assessment and consideration of the impact of other relevant factors. 

All  of  the  above  was  taken  into  consideration,  when  preparing  the  proposals  for  the 
multiannual financial framework and the CAP 2028-2034. 

11