This investigation was developed with the support of Journalismfund Europe and originally published in the EUObserver.
Lawyers have called it undemocratic. The EU’s watchdog has found maladministration. Two years after a wave of farmer protests swept across Europe, the political response that dismantled key environmental measures in the EU’s most expensive policy at breakneck speed has left an indelible mark on decision-making in Brussels. But just how this happened – and who had a place at the decision-making table – remains far less clear.
In this investigation, we trace the closed-door discussions via exclusive interviews and insights that led to the rapid rewriting of EU farm policy at the height of the so-called farming ‘crisis’ and dig into the moment that broke new ground for EU policymaking.
Natasha Foote reports.
It is rare that the ‘making of the sausage’ is so literal. Yet, it was while eating sausages with farmers at the side of the road in Szczecin, Poland, some 900km from Brussels on a rainy day early in 2024, that the simplification story first started for the then-Agriculture Commissioner Janusz Wojciechowski.
“There was a big blockade of the highway,” he recalled in an exclusive interview, adding that he decided to go alone to “find out what the farmers were asking for”. This was, as he sees it, part of the ‘special’ close role of the Polish Commissioner with Polish farmers.
If national protests were the spark, tractors in Brussels helped light the fuse that kickstarted the rapid dismantling of the environmental elements of the EU’s €300 billion farming subsidy programme, the Common Agricultural Policy (CAP), in the following months.
The moment broke new ground, literally and figuratively, for EU policymaking. It is here that the blueprint for the EU’s simplification agenda was drawn, charting the course for what has since become a well-trodden path: the use of legislative ‘omnibus’ packages to fast-track environmental changes under the banner of simplification.
Setting (Tractor) Wheels in Motion
For the ex-Commissioner, the driving force behind the changes is clear: “farmers’ pressure”. “I can say that it was the success of the farmers’ demonstration,” he said, recalling that he “declared for the farmers, ‘I agree and I will do everything which is possible to do”.
Meanwhile, Wojciechowski describes busying himself with “many visits, many meetings with the farmers in member states”.
Which farmers, and whose voice was at the table, has been the topic of intense scrutiny ever since, with civil society groups vocal in their criticism of the lack of a formal consultation process. In comparison, the previous reform garnered input from over 300,000 stakeholders.
And it is those conversations, he says, that set the wheels in motion for reopening the basic legal acts of the farming policy — a previously ‘unthinkable’ step according to one EU diplomat, who was closely involved in the negotiations and was granted anonymity in order to speak freely. “In the past, there was really no appetite from the Commission for this,” he said, warning of a legal ‘Pandora’s box’.
Documents obtained via a Freedom of Information request as part of this investigation show meetings between the Commissioner and farmers’ groups, including EU farmers’ association Copa-Cogeca and national representations from Spain, Poland and Italy, as well as only one political group: the hard-right European Conservatives and Reformists Group (ECR). There is only one recorded meeting with an NGO during that time period, with animal welfare lobby Eurogroup for Animals.
Wojciechowski himself did not cite or recall meetings with other civil society groups or experts around the time of the protest. “Oh, maybe that’s… You’re right, because it was a very quick procedure,” the ex-farming chief said when questioned on the consultation process.
Asked for comment, a Commission spokesperson explained that “when time is short, full public consultations are not always possible”. “This is how the Commission answers pressing challenges while keeping decision making anchored in evidence and accountability,” the spokesperson said.
‘Worrying precedent’
But, for ClientEarth lawyer and CAP specialist Sarah Martin, the lack of consultation process sets a “worrying” precedent. Calling the process “undemocratic”, Martin argues the move goes against the “public’s right to democratically participate in the EU decision-making process”. Her legal reading is clear: “The urgency procedure should not have been adopted”.
This led ClientEarth, alongside environmental organisation BirdLife, to lodge an official complaint to the EU’s watchdog, the Ombudsman.
The Ombudsman’s verdict, delivered in November 2025, found a “number of procedural shortcomings in how the Commission prepared the legislative proposals” which, taken together, “amount to maladministration”.
In particular, the watchdog notes that the EU executive had applied a “particularly broad definition of ‘urgency’,” failing to “sufficiently justify invoking urgency to derogate from its internal decision-making rules”.
While not binding, the EU’s guidelines for fair policy making stipulate an impact assessment and stakeholder consultations should accompany any major EU policy initiative expected to have significant economic, social or environmental effects. The last formal impact assessment of the EU’s current €300 billion policy was conducted in 2018.
While Wojciechowski “fully agree[s] that the impact assessment is very important […] in normal conditions, with “the situation [in 2024], and the farmers’ demonstration, it was necessary to proceed”. The ex-Commissioner, who has a background in law and is currently pursuing a legal career in post-Commission life, called it a “political decision and an unusual situation”.
Likewise, the Commission argues that the lack of impact assessment is justified due to the “political urgency of tabling this proposal, which aimed to respond to a crisis situation in EU agriculture”. No definition of political urgency or crisis was specified.
While there is “room to improve certain procedural aspects”, the EU executive maintains procedural shortcomings “had no bearing on the quality of our proposal or of the evidence underpinning it”.
But for ClientEarth’s Martin, the “arbitrary” nature of what constitutes a crisis is cause for concern.
“Is the justification of tractors on the street enough to reopen the legal basis of a policy that’s worth a third of the EU budget?” she queried. “If that’s all it takes […] for political urgency, we’ll just put tractors on the street whenever we want to reopen environmental legislation or do whatever we want. That’s a very worrying precedent.”
Yet by all accounts, the protests made their mark in Brussels. “We were about to cancel the February council […] but it was clear that we had to contain it as much as we could, because the police were very nervous. They said ‘do everything so they leave as soon as possible and as appeased as possible’,” the diplomat recalls.
In his view, there was a “direct line with von der Leyen’s cabinet and the push to appease the farmers,” he said, pointing out that, in February 2024, European Commission president Ursula von der Leyen was busy preparing the ground for her eventual re-election in the summer of that year.
Taken together, this added up to the Commission “giv[ing] in very quickly”. “It was one big day of protest. That puts a lot of pressure, but I remember far larger protests for different reasons,” he noted.
Legal Wrangling
Meanwhile, the response to a Freedom of Information request, opened as part of this investigation, shows no trace of correspondence with legal services or lawyers, internal or otherwise, around the time of the proposal.
Asked for comment, a Commission spokesperson said that the Commission has “well-defined internal procedures for the preparation of Commission documents which includes interservice consultations” that “apply to all legal proposals adopted by the College”.
However, the absence of legal counsel reflects accounts from multiple sources inside the Commission. “There was nothing, no process, no impact assessment – it was all done under the duress of the farmers’ protest,” one Commission insider, who chose to remain anonymous, said.
Another Commission source maintained they raised concerns of the legality of a subsequent change to the CAP, but was instructed to “find a way around it”. “There is a culture of fear – nobody speaking out, the ones that are have been quietly moved to other positions,” the insider said, citing a “change in the political climate”.
Ploughing ahead
With the “pressure on” to come up with proposals, the EU diplomat said the Commission requested input from both member states as well as from farmers’ associations – a process “done in a rush”. “We got all this input from the 26 other member states, and we could do nothing more than just bundle it. But it was going in all directions,” he said.
The diplomat then detailed how the Council “sat together” with then-chair of the Parliament’s agriculture committee, Norbert Lins to check if they were “on the same page”.
The move breaks from common EU legislative convention. Lawmakers usually each secure their own position and then compare notes before working towards a compromise. This can be a drawn out process; the most recent CAP reform, for example, took 4 years of negotiations to seal a deal. By aligning positions ahead of the negotiation, lawmakers could push through the changes in under 4 weeks.
While Lins maintains there were “no formal meetings,” he agrees the two sides “agreed to go for urgent procedure,” noting the “increased pressure to do something”.
“We were a few months before the European elections. And then the agriculture politicians in all the institutions [European Council, Commission, and Parliament] saw that we have to do something. When we were talking to the farmers, we saw the necessity to change some rules”. This is a process he says from the Parliament’s side “took a few days”.
With the Parliament helping drive the change, the lawmaker does “not see a lack of democracy or […] undemocratic decision-making process”.
Greener Pastures?
The full fallout from the decisions made around the protest has yet to be fully explored, according to agricultural economist Doris Läpple. The researcher co-authored recent research exploring the impact of the farmers’ protest across four EU countries – Germany, France, Belgium, and the Netherlands – via over 2,000 farmer surveys.
The paper concludes that “little is known about underlying motivations and individual farmers’ reasons for protesting”.
Moreover, environmental conditions or measures were, in “none of the countries, the key reasons to protest,” she said. While low farm incomes and restrictive environmental regulations were “commonly cited grievances” among farmers, environmental conditions or measures “was not a primary concern of farmers” in any of the countries surveyed.
In Germany, for instance, bureaucracy was the main complaint. However, in all except Belgium, environmental issues were “overly emphasised by policymakers,” Läpple said, with environmental complaints “disproportionately prioritised by EU policymakers and some Member States” according to the research. This trend was found to be particularly pronounced at the EU level.
For Läpple, this indicates a “gap” between the farmers on the ground, the lobbies that purport to represent them, and the policymakers. “But we didn’t feel that [environmental measures] was as much in our data as it was prominent in those farmers union’s claims,” she said.
The only common position prevalent in farmers’ responses from all four countries was that national and EU policymakers “have no idea about what they’re talking about,” she added.
A Lasting Legacy
It is this policy rollback that laid the groundwork for the Commission’s wider simplification agenda to take root. Since then, ten omnibus regulations—cross-cutting legislative packages designed to reduce administrative burdens and simplify EU law—have followed, with more in the pipeline. The changes are far-reaching, touching everything from pesticides and industrial emissions to digital policy.
And it is on this backdrop that work is underway on the overhaul of the farming subsidy programme post-2027, building on the foundations laid by this simplification.
Asked how the watchdog’s findings will impact future decisions, a Commission spokesperson said the Commission will use the Ombudsman’s recommendations to “make these procedures even clearer and more predictable for future accelerated work,” stressing the “importance of ensuring derogations from its standard policy-making rules in the case of urgency are properly recorded and explained”.
As part of its plans to revise these internal rules, the Commission also indicated it will “reflect on ways to be more transparent in its assessments of the need to act urgently”.
Responding to concerns raised, current agriculture commissioner Christophe Hansen said that simplification “should not be about weakening standards”. Instead, it should be a “deeper look into what is benefitting and not benefitting [farmers]” with the aim to fix rules that “were not helpful and contributed to a lot of mistrust,” he said, adding this is “one of the reasons farmers took to the streets”. He argues the need to go further, looking not only at the CAP but also overlapping environmental legislation.
Yet despite new strategic dialogues and structures such as the European Board of Agriculture and Food, civil society groups warn that meaningful participation remains limited in the ongoing push to streamline policies.
For Alberto Alemanno, legal expert and founder of the advocacy organisation the Good Lobby, it is a sign that “democratic safeguards risk becoming optional”.
“We are institutionalising exceptions,” he said during a recent Good Lobby press conference, calling it a “very dangerous form of institutional self-sabotage”. “Make no mistake, this is not really about better regulation. It’s about less accountable governance,” he concluded.
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