AUTHORS: Melanie Muro, Elisabet Nadeu, Axel Godfroy

On 14 May 2025, the EU proposed major CAP reforms to cut red tape and boost flexibility but some changes may risk weakening environmental requirements, long-term policy coherence and ignore calls for regulatory stability.

On 14 May 2025, the European Commission published a Simplification Package proposing 25 amendments to the Common Agricultural Policy (CAP) legislation. The stated rationale for these changes is threefold: simplifying CAP implementation, enhancing the competitiveness of farmers and strengthening their resilience to withstand future economic and climate-related crises. These reforms are the latest in a series of actions taken by the Commission to simplify the CAP legal framework and alleviate administrative burdens on farmers and national administrations in response to various challenges raised by these groups.

In 2024, the Commission adopted a first CAP Simplification Package which mainly focused on removing and allowing more flexibilities in the implementation of environmental standards. A roadmap setting out plans to revise secondary legislation was launched alongside the most recent simplification proposal, indicating that further revisions of the existing legal framework governing agriculture in the EU can be expected.

Among the most significant changes proposed through this round of simplification measures are:

1. Administrative simplification
   • Limit on on-farm inspections to one per year.
   • Removal of annual performance clearance, reducing reporting obligations.
   • Simplified amendment process for CAP Strategic Plans; non-strategic changes no longer require Commission approval.
   • No requirement to update CAP Strategic Plans in response to new EU environmental or climate legislation during this CAP period.
2. Adjustments to good agricultural and environmental conditions (GAEC)
   • Organic farmers can automatically be considered as compliant with several GAEC standards beyond GAEC 7.
   • For GAEC 1, Member States may increase the allowable reduction in permanent grassland before triggering reconversion requirements from 5% to 10%,. In addition, the timeframe for classifying land as permanent grassland is extended from five to seven years, giving farmers more time before such designation takes effect.
   • For GAEC 4, Member States will be allowed to align definitions of watercourses with national legislation while maintaining environmental protection.
   • For GAEC2, the Member States will be allowed to exclude GAEC 2 (protection of wetlands and peatlands) from the conditionality baseline enabling farmers to receive eco-scheme payments for actions that would otherwise be considered mandatory under GAEC rules, such as basic wetland protection.
3. Support for small and organic farms
   • Increased lump-sum payment for small farmers from €1,250 to €2,500.
   • Permit annual payments per livestock unit to support both conversion to and maintenance of organic practices, recognising the specific cost structures involved
   • New option introduced for annual payments per beehive, recognising the environmental benefits of beekeeping and its difference from typical livestock farming.
4. Crisis support and financial Instruments
   • Agricultural reserve to be re-focused solely on market disturbances, its original purpose.
   • New crisis payments allowed under direct payments and rural development for natural disasters and extreme weather events capped at max. 3 % of the total of direct payments and EAFRD. Due to their emergency nature, the new crisis payments are exempt from standard and social conditionality, allowing faster support with less bureaucracy.
   • National co-financing of up to 200% permitted for crisis payments to improve responsiveness and impact.

Several of the proposed changes, such as recognising farmers certified under that Organic Regulation as meeting key environmental conditions, and permitting non-strategic amendments to CAP Strategic Plans without prior Commission approval represent meaningful steps toward reducing red tape and increasing flexibility. However, some of these changes might warrant further clarifications. For instance, it will be essential to clearly define what qualifies as a “non-strategic” amendment to CAP Strategic Plans, to ensure that increased flexibility does not compromise oversight.

The package also raises important concerns regarding long-term sustainability, resilience and policy coherence.

Firstly, recent statements by the EU’s Commissioner for Agriculture and strategic documents, most notably the Vision for Agriculture and Food, have clearly signaled an ambition to move away from regulatory instruments and towards more effective incentives for sustainable farming. However, several proposed changes may weaken the capacity of the CAP to drive systemic transformation. Allowing CAP payments for actions that merely meet regulatory requirements, as proposed for GAEC2, rather than exceed them, puts in question one of the basic principles for all payment schemes, namely that actions supported should deliver added value beyond compliance. Furthermore, dedicating part of the CAP budget to a new crisis reserve for climate-related events, while understandable to provide short-term economic support, should align with, rather than undermine or reduce, the funding available for schemes that have the capacity to build structural resilience and mitigate future climate risks.

Secondly, the introduction of this new simplification package mid-way through the current 2023–2027 CAP period and the EU’s Multiannual Financial Framework (MFF) adds further complexity to an already evolving policy landscape. Farmers and national administrations have consistently called for regulatory stability. Frequent changes, even when well-intentioned, create uncertainty that can undermine strategic planning and investment.

Thirdly, the proposed removal of the requirement to update CAP Strategic Plans in line with new EU environmental and climate legislation sends an unhelpful signal about the importance of environmental integration. It contradicts repeated calls for greater alignment between these policy areas and related targets.

Finally, while simplification is welcome, and in many cases necessary, it cannot solve the multi-faceted challenges faced by EU agriculture. Addressing these structural challenges, from biodiversity loss and climate change to generational renewal and market volatility, requires more than bureaucratic easing and streamlined procedures. It demands a stable, coherent, forward-looking policy framework with clear, quantified objectives and targeted funding that supports farmers in making the long-term shifts needed for sustainable and resilient food systems.

Photo by Dan Meyers on Unsplash