The EU’s simplification package on the Common Agricultural Policy: Simplification or Deregulation?

The most recent and second CAP simplification package proposes a set of targeted changes to the CAP legislation and is part of a broader agenda by the current Commission to cut red tape and reduce the bureaucracy of EU legislation. The aim of the proposal is to boost the competitiveness of EU farms, to improve the implementation of the CAP and to reduce the overall burden for national administrations and farmers.

In 2024, the Commission introduced a first CAP simplification package in response to widespread protests from farmers across Europe who were voicing frustration over regulatory complexity, environmental obligations, and financial pressures. In this context, the Commission launched the Strategic Dialogue on the Future of Agriculture in early 2024 to foster inclusive discussion among stakeholders, including farmers, policymakers, and other agri-food stakeholders, on how to balance food security, environmental sustainability, and rural development in future EU agricultural policy. Drawing on the outcomes of the strategic dialogue, the debate on simplifying the CAP has continued throughout 2025 with the Commission planning further revisions to the EU’s agricultural policy framework until the end of the year.

Overall, small and organic farmers are the big winners of the second CAP simplification package as they will benefit from increased financial support and reduced burden when it comes to complying with environmental standards. With fewer on-site controls and more exemptions, the Commission seems to hope to strike a better balance between requirements and incentives.

One central objective of this second simplification package is to reduce the need for controls and checks on farmers by establishing a limit of one on farm control per year. In addition, the Commission is planning to increase the lump-sum payments offered to small farmers from 1250EUR to 2500 EUR and to exempt them from controls and administrative penalties. The draft also suggests that organic farmers would automatically comply with several good agricultural and environmental condition” of land (so-called “GAECs”) standards if their entire farm is certified organic while livestock farmers converting to or maintaining organic farming practices are promised more financial support in the form of an annual payment for livestock units.

Currently, there are nine mandatory GAECs which farmers must comply with to receive CAP income support. Despite their crucial role in protecting nature, reducing pollution and strengthening farmer’s resilience to cope with the impacts of climate change, the Commission’s CAP simplification package proposes to relax these environmental standards.

The proposed adjustments would weaken the protection of grasslands by allowing up to 10% of these areas to be degraded, instead of the current limit of 5%, before farmers are obliged to reconvert agricultural land back to permanent grassland. Relaxing the rules on permanent grassland is not only driving biodiversity loss but also poses a significant environmental risk, given their vital role as carbon sinks.

In addition, the proposal suggests that member states could be allowed to pay farmers to merely comply with the requirements of protecting wetlands and peatlands under eco-schemes and rural development interventions. This means farmers will receive funding for these schemes without having to go beyond the conditionality baseline. When peatlands and wetlands are drained for farming activities, they release large amounts of CO2 and N2O, hence it remains important to further incentivise active rewetting and restoration of these carbon-rich ecosystems.

Finally, the Commission is planning to make changes regarding rules establishing buffer strips between agricultural land and water courses. Under GAEC 4, farmers are usually required to use no fertilisers or pesticides on at least three metres of buffer strips along rivers and other water bodies to prevent pollutant run-off into surface water. Here, member states will be given more flexibility to define what constitutes a watercourse based on their national legislation, if it is “in line with the main objective of that GAEC standard, in particular to reduce the risk of excluding smaller water courses, that could carry pollution downstream.”

The Commission justifies its overhaul of the EU’s farming system with need to balance environmental protection and the realities of farming. But we should be careful.

And the consequences are complex: it will ultimately undermine the long-term resilience and competitiveness of the agri-food sector by further eroding the eco-systems our agricultural systems deeply depend on.

The proposed deletion of the CAP Strategic Plan review mechanisms[1] could mark a significant shift in how the national CAP Strategic Plans interact with evolving environmental and climate legislation. Originally, the Strategic Plan regulation ensured that member states would assess and, if necessary, revise their plans to align with changes in relevant EU green legislation, listed in a specific annex of the regulation and to be updated by the Commission through a legislative proposal. The idea was to ensure that the CAP Strategic Plans remained coherent with incremental translation in EU law of the Green Deal, Farm to Fork and the Biodiversity Strategy objectives over the course of the 2023-2027 programming period.

Deleting such mechanisms, as outlined in the internal assessment by DG AGRI, would carry more political weight than it would have legal implications. The deletion would not affect in any way the Commission’s powers under the EU Treaties to propose amendments to legislative texts and therefore potentially expand the list of relevant environmental and climate legislation at any time.

However, it would signal that the Commission no longer sees such changes as politically viable.

If no adaptation of the list is foreseen, it logically follows that the obligation for member states to align their plans accordingly becomes irrelevant.

While the Commission’s reasoning is that any strategic modifications to national plans during the remaining CAP implementation period would be “highly disruptive for national authorities and farmers”, this decision risks creating a significant lack of policy coherence by disconnecting crucial new environmental and climate legislation from the national Strategic Plans. As a result, member states’ plans may either contradict or fail to support the environmental, climate and biodiversity goals established by those new pieces of legislation.

The Commission’s proposal to distinguish between strategic amendments and other types of amendments to national strategic plans reflects a shift towards greater national flexibility.

It also signals a reduction in EU-level oversight by the European Commission over potential key policy changes at national level.

In the current version of the Strategic Plans regulation national authorities must justify amendments to their Plans and provide necessary information to assess the proposed changes, including expected impacts on climate mitigation, adaptation, and biodiversity. Based on this, the Commission then evaluate the amendment request. In the proposed new formulation, this procedure is no longer the norm but rather the exception. Only strategic amendments concerning substantial changes to a Plan’s core logic (introducing or removing interventions, altering milestones and targets, or modifying significant financial elements) would be assessed and approved by the Commission. Such amendments would only take effect once approved, while regular amendments would only require a notification to the Commission. Non-strategic amendments that may negatively affect, for example, standards on soil erosion (GAEC 5), soil cover (GAEC 6), or crop rotation (GAEC 7) could enter into force without member states being required to provide justifications to the Commission.

For non-strategic amendments, the Commission’s oversight power is limited to raising objections within 30 days following the notification. However, by that time, the amendments may already be applied at national level, with farmers already implementing the revised rules. Should the Commission, however, object to the amendment, any cost resulting from it would not be covered by CAP fundings. This situation risks could introduce an unnecessary element of unpredictability into the CAP framework.

The Commission did not carry out an impact assessment to analyse the implication of its simplification package – with the argument of urgency. 

A similar rationale was already invoked for the first CAP simplification package adopted in 2024 and following farmer protests.[2]

Impact assessments are meant to inform the Commission with the best available evidence, assess “the environmental, social and economic impacts of a range of policy options”, and ultimately ensures that policies are evidence-based and aligned with the objective of “mainstreaming sustainability into Union policymaking”. They cannot be replaced by a staff working document, which in this case mainly evaluates potential reductions in administrative costs.  

The lack of a comprehensive assessment raises serious concerns, especially given the potential consequences of the proposed changes. For instance, the potential harmful environmental impacts of relaxing the GAEC standards remain unclear. It also undermines the Commission’s own commitment to transparency and to the principle of “better regulation”.

As a next step, the Commission’s proposal will go to the European Parliament and the Council of the European Union for their consideration and adoption. Both institutions can amend the proposal or alternatively choose to accelerate the procedure by directly adopting the proposed text without amendments. The Parliament could also resort to its urgent procedure, as it did just a year ago with the first CAP simplification package. While this fast-track procedure allows for a rapid adoption of the package, it drew criticism due to the limited the time available for scrutiny and debate over important legislative changes.

Alongside the most recent CAP simplification package, the Commission is already working on the EU long-term budget (the Multiannual Financial Framework, MFF) proposal, which is expected in July and will determine the financial envelope of the post-2027 CAP. The Commission’s plan to consolidate various funding streams, including the CAP, the Cohesion Policy, and EU research funding Horizon Europe, into a single fund has sparked strong opposition from farmers who have returned to the streets of Brussels, calling for a dedicated CAP budget. It therefore remains to be seen whether the EU’s agrifood policy will continue to bolster farmers’ interests in the near future, or whether environmental considerations will gain more traction.

[1] Articles 120 and 159 of the CAP Strategic Plans Regulation
[2] “With a view to the political urgency of tabling this proposal, which aims to respond to a crisis situation in EU agriculture, no impact assessment has been carried out, as foreseen in Tool #1 of the Commission’s ‘better regulation’ guidelines that stipulates the importance of their flexible and proportionate application.” European Commission (2024), “Proposal for a Regulation Of The European Parliament And Of The Council amending Regulations (EU) 2021/2115 and (EU) 2021/2116, COM(2024) 139 final”.