Why Simplification of CAP May Get Complicated

A simpler, streamlined EU farming subsidy programme can only be a good thing … right? Well, it’s a bit more complicated than that. Here, Natasha Foote digs into what we currently know about the next simplification shake up of the Common Agricultural Policy and why keeping it simple is not always so straightforward. 

For the second time in two years, EU agrifood policy is set for a simplification shake up with the announcement of two shiny new packages. The first, expected in the second quarter of this year (most likely sometime in May), will come for the CAP, with a second targeting environmental and food safety policies beyond the CAP to follow sometime towards the end of 2025.

The idea is to streamline legislation, making life simpler for farmers and those receiving EU funds. 

Given the rising frustrations among farmer communities over mounting paperwork, at first glance this seems like a positive step. But you don’t have to scratch too far below the surface to see that all that glitters is not gold

How did we get here?

The issue of burdensome administration was already put on the table back in 2024 thanks to the farmers’ protests, where red tape was a core driver of the frustration across farmers’ groups of all shapes, stripes and sizes. Then came the publication of the EU’s seminal ‘Draghi’ report on competitiveness, which has essentially become the new blueprint for EU policy going forward. And the report really does not like what it sees as the EU’s regulatory burden, especially when it comes to sustainability reporting and requirements. 

Ever since, simplification has become the name of the game for the Commission. And, because this new Commission seems particularly partial to transport analogies, this then set the wheels in motion for a new simplification ‘omnibus’, which is when a series of legislation is passed at the same time to accomplish the same goal.

The first stop on the omnibus policy tour was the EU’s sustainability policies (more on this below), with the CAP up next in the drive to ease regulatory burdens. 

In and of itself, simpler does not necessarily mean anything sinister. But, as the adage goes, the road to hell is paved with good intentions – and far from smooth sailing, we can already foresee road bumps up ahead

Start as you mean to go on

The Commission has repeatedly promised that de-bureaucratisation will not mean deregulation – but what we’ve seen so far suggests otherwise

First is that this is not our first rodeo. We already had a glimpse of what a streamlining of the CAP looks like back in 2024 – aka, a rapid re-opening of the legal basis of the CAP to push through a dismantling of green rules in response to the farmers’ protests. 

The second is that we have already seen what happened in the first leg of the omnibus tourand safe to say we’re not off to a promising start

The first laws to be thrown under the omnibus include those on corporate sustainability reporting (the catchy CSRD) and due diligence (the even-catchier CSDDD); the EU green taxonomy, a classification system to help clarify what economic activities are sustainable and prevent greenwashing; and the Carbon Border Adjustment Mechanism (CBAM), a policy tool by the EU to ensure a fair price for carbon emissions embedded in imported goods.

In the same spirit as the Commission, let’s put it simply – the revisions fundamentally weakened the laws, removing key provisions and narrowing obligations for companies to address human rights and environmental risks in their supply chains.

For example, the EU omnibus proposal removes around 80% of companies from the scope of the CSRD rules and postpones reporting requirements for companies set to report in 2026 or 2027 by two years. 

Interestingly, the changes have sparked consternation not only from green groups, but also from investors, who have argued that the rapidly changing conditions give no security to potential investments, as well as industry groups, some of which had already started investing in the necessary changes. 

All of this is framed in an all-too-familiar need for speed. Forget the lengthy and considered public consultations – much like with the first changes to the CAP, these omnibus simplifications were pushed through in fewer than 24 hours over a weekend. All this suggests that the lack of transparency and undue haste that critics have been warning about will likely be an ongoing theme. 

Meanwhile, as green campaigners point out, promises that the upcoming changes will not affect the CAP’s environmental and climate ambition have not been substantiated by any impact assessment or real data – something that is again, all too familiar.

As simple as C-A-P

So far, the Commission is keeping quiet on the details of what this CAP simplification could look like, but there are plenty of clues we can look at to point us in the right direction.

Sources close to the matter say that the Commission is drawing inspiration from simplification suggestions from member states, the Parliament’s agriculture committee and farmer organisations. A Commission source added that they are “examining suggestions” provided by member states following the January 2025 meeting of EU agriculture ministers. 

excerpt from conclusions from the January 2025 meeting of EU agriculture ministers

The conclusions from that meeting suggest that agriculture ministers are looking at further simplifications in the green architecture of the CAP.

“There is also room for further simplification in the management of the strategic plans, so as to enable Member States to efficiently respond to emergency situations and eliminate ineffective green provisions unreasonably limiting agricultural production,” the document, which you can see above, reads. 

Suggestions include the introduction of lump sum payments for eco-schemes, ways to increase the flexibility of support systems, and alternative ways to finance environmental requirements. Ministers also suggest that changes to the CAP strategic plans should be faster, giving EU countries more control to make quick changes “more frequently” (because everyone loves a fast-moving goalpost).

But, tellingly, ministers’ musings also include going one step further to simplify environmental requirements. This includes, for example, another rethink of the good environmental and agricultural conditions (GAECs), many of which have already been fundamentally changed

This time ministers suggest targeting GAEC number 2, which relates to protection of wetlands and peatlands, arguing that a similar obligation has been introduced under the Nature Restoration Law

The seemingly innocuous line suggest that more changes could be coming for the GAECs – and, as ARC2020 recently pointed out, the stakes are high when it comes to peatlands, which make up less than 3% of all of the earth’s surface but store up to 30% of all territorial carbon – more even than the world’s forests combined. 

Alarm bells ringing

The promises of another round of simplification has been enough to trigger more than 60 environmental and agricultural NGOs to join forces in a statement stressing that dismantling environmental rules will hinder rather than help farmers

The letter, which was published on 18 March, urges the Commission not to further weaken the EU legal framework for the remaining GAEC standards. “Weakening or removing processes and instruments designed to ensure the achievement of the CAP objectives is unacceptable and counterproductive to both farmers and the public,” the letter states. 

The simplification focus should instead be on “harmonising reporting processes, enhancing the digitalisation of systems, and effectively communicating and clarifying the rules for proper implementation,” signatories argue. 

While the groups acknowledge there may be a need to simplify annual performance reports, they “strongly oppose their complete suspension,” arguing that, in a context of mounting pressure on public budgets, it is “crucial to accurately monitor how funds are spent”. 

Meanwhile, small farmers association European Via Campesina and EU organics association IFOAM have repeatedly warned in the past that, while reducing administrative burdens for farmers is necessary, simplification must not come at the cost of lower environmental ambitions and further exacerbation of the impact of climate change and of the biodiversity collapse that farmers already witness. 

Time will tell exactly what fun is in store for this next round of CAP simplification – but so far, all indications suggest that the farming policy may well be the next to be thrown under the EU omnibus.

This article is produced in cooperation with the
Heinrich Böll Stiftung European Union.

 

 

 

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About Natasha Foote 72 Articles

Natasha is a freelance journalist, podcaster and moderator specialising in EU agrifood policy. She previously worked as an agrifood journalist with the EU media EURACTIV, and before that spent several years working on farms around Europe to learn more about the realities for farmers on the ground. Natasha holds a Master’s degree in Environment, Development and Policy with distinction from the University of Sussex, where she worked on food issues and alternative approaches to food production.