Specific Details
Common Agricultural Policy (CAP) & Agricultural Simplification Measures
Intended results
To put forward proposals to Irish MEPs in advance of the potential Agricultural Simplification Package expected in Quarter 2 2025 in the European Parliament.
Beneficiaries of Simplification Measures
That the primary beneficiary of CAP Simplification efforts must be the active farmer. They are the ones, through CAP, charged with verifying on-farm actions while manoeuvring ever volatile and uncertain operating conditions, amid ever growing standards, regulations and expectations, to consistently support and deliver food security and multiple societal demands without any financial certainty themselves.
Need for Common Agricultural Policy (CAP) Simplification
That CAP remains integral to the economic sustainability of most farms across almost all farm sectors. It has however, transitioned from a food production and income support policy for EU farmers to a complex, administratively complicated environmental payments model. The next CAP must revert to the original purpose of the Policy, ensuring a fair income for farm families and high-quality affordable food for EU citizens produced by EU farmers by directly supporting farm production.
A separate fund, as recommended by a recent Commission Strategic Dialogue on the Future of EU Agriculture and Food is needed to support environmental action.
This cannot simply mean a carve-out of existing environmental supports and a reduced allocation for CAP. More, not less, is required. The value of CAP has been in decline in real terms for almost two decades, compounded at farm level by a 73% increase in the cost of production in recent years. Securing a strong allocated budget within the Multi-annual Financial Framework for CAP mid-2025 will be essential.
Proposed Simplification Measures
• Greater proactive engagement with farmers and/or their representatives well in advance of design of CAP Strategic Plans and individual measures therein to ascertain the on-farm impact and practical viability of proposals from all perspectives. This will minimise the necessary ‘simplification' efforts required subsequently;
• In terms of administration, the net benefit at farm level from scheme participation has been impacted by the income foregone/cost incurred approach, adding costs, complexity and ‘leakage of CAP funds' away from primary producers to contracted third parties. This needs to be reviewed and reversed, with consideration given toward including an incentivised approach alongside generous universal participatory payments.
• With multiple schemes and payments now replacing their predecessors – e.g. BISS/ CRISS/Eco-scheme vs BPS/Greening, it is more difficult for farmers to keep track of payment receipts. Increasing qualifying rates and reducing the volume of individual schemes may also be considered, easing the administrative burden on farmers and paying agencies alike.
• Schemes that are attractive to farmers, and working well in terms of meeting objectives and payment delivery timelines should be replicated and renewed at elevated rates. Schemes causing issue, such as ACRES in the case of Ireland, should be reviewed and material changes swiftly enforced to eliminate blockages and therein maximise resource efficiency; strengthen loyalty; scheme participation and financial return. Similar approach re performing Conditionality standards should be applied, which
• Permit contractual actions over the lifetime of scheme participation and permit utilisation of geo-tagged photos as verification means toward swift payment. Apply/rely upon limited volumes of ex-post inspections where necessary.
• All farmers should get at least 70% of their BISS payment in mid-October. Issues arising thereafter can be resolved from the balancing payment.
• The option of introducing more coupled payments must be considered in targeting support to active farmers in vulnerable sectors. Verification per DAFM/Industry datasets would be readily available and easily delivered.
• Proactive individualised communications with farmers in advance of action deadlines so as to minimise noncompliance and/or associated appeals/penalties etc.
• CAP Strategic Plans (CSP) contain all the details of how the CAP is to be applied in each Member State. Greater flexibility, without need for Commission approval, should be provided with regard to its implementation at local level.
• Social conditionality – farmers should not be subject to double payments. If a farmer makes a mistake, they cannot be sanctioned on CAP payments and through national legislation related to working conditions. This should be amended immediately.
That, in terms of proposed future CAP reform/simplification measures and specifically the possibility of capping payments, consideration must be given to leased-in entitlements; family employment and/or situations (e.g. Registered Farm Partnerships) where more than one income is being earned from the farm to avoid any unintended consequences.
Past simplification efforts, while demonstration of excessive administration burden and changed approach from Commission officials, offered little benefit to Irish farmers relative to their European counterparts. GAEC 8 specifically carries little to no significance for Irish Agriculture given the already high percentage space for nature present on Irish farms.
One element which would have been beneficial was with regard GAEC-2 (Protection of Peatlands and Wetlands). IFA has consistently been calling for a derogation or postponement of the implementation of GAEC 2 given its disproportionate impact on Ireland, and the potential severe socio-economic effects its implementation may have on Irish farmers. IF
IFA remain of the view that before any GAEC 2 standard is applied in Ireland, its economic impact must be clearly understood. The same carries through for any proposed amendment to the CSP.
Pertaining specifically to other Conditionality measures
- GAEC 7 A continuation of the derogation from GAEC 7 requirements of the three-crop rule and a review of crop diversification requirements should also take place in 2025.
- GAEC 6 The requirement under GAEC 6 to have a 30% grassland/stubble lie-back when grazing forage/ catch crops with livestock has added a layer of complexity and impacted the sustainable practice of integrating livestock into cropping systems. This should be corrected and reduced significantly.
That it is especially important to keep the CAP a policy in its own right – a partnership between agriculture and society, and between Europe and its farmers in order to ensure the sustainability of agriculture and food production, with the main focus on ensuring food security, a stable and affordable supply of food produced at high standards.
Recently, there have been suggestions that there may be considerable budgetary overhauls planned for the next EU Budget post-2027, with EU money streams possibly centralised and condensed into funding pots, moving away from a programme-based approach to a policy-based approach. This would bring programmes like CAP, Cohesion, Regional Development and Fisheries into one, and payments to Member States would be linked to EU-determined outcomes.
Funding, per the CAP Strategic Plan approach, could be based on National Development Plans and green-lit by the Commission before they are implemented. As noted earlier, while perhaps beneficial from paying agency perspective, it would be detrimental potentially to EU farmers; the competitiveness and income security CAP provides.
This approach should be resisted, unless provision is provided for ring-fenced amounts (equivalent at least to existing CAP receipts) so that farmers are not disadvantaged, given their strategic importance. A strongly funded Rural Development Programme (RDP) under Pillar II is vital for rural areas. Funding must be made up from a high EU contribution combined with significant national co-financing.
Broadly with regard improved on-farm competitiveness, please see below for consideration
• Any regulatory changes imposed on farmers either through national or European policy changes must have a prior income impact assessment completed.
• Regulations relating to farming have been in a constant state of flux over the past five years in particular. This is creating huge uncertainty amongst farmers making medium-term planning very difficult. This in turn is having a knock-on impact of farm efficiencies. A period of stability is now required with a pause to any further regulatory changes badly needed.
• Given the crisis in farm incomes, particularly among the vulnerable sectors, it is critical that the Government step up its support to the vulnerable sectors to ensure their survival. It is also critical that any support schemes provided to small businesses do not exclude farmers as farm businesses are suffering from the same increased costs as small businesses in other sectors of the Irish Economy.
• Farm incomes should be benchmarked to the average industrial wage on an ongoing basis. This would allow a proper comparative analysis of the performance of farm incomes compared with average wages in the wider economy.
• Any move toward full convergence should only occur through an increase in the CAP budget. It must not be funded again by further cuts to farmers with per hectare payments above the average, with no consideration given to actual amounts received nor its relation to on-farm viability. Many of our most progressive farmers, including many small-scale operations, particularly in the most vulnerable farm sectors, suffered the most as a result of this approach.
The objective of increasing the payments per hectare for genuine farmers with payments below the national average must be upwards only adjustments in payments per hectare.
• The Irish Government must invest in agriculture and support farm incomes/viability by providing the maximum permissible level of national co-financing to deliver essential targeted sectoral supports sucklers (€300/ cow), sheep (€30/ewe [€40/hill sheep]), tillage (€250/ ha for Tillage Survival Scheme in 2024; €400/ha in 2025 [€250/ ha in 2026-2028] for additional [and retained] cereal crops grown), calf rearing (€100/dairy beef calf); beef sustainability (€100 per dairy and suckling yearling).
• Whole farm environmental schemes, similar to REPS, with a minimum payment of €15,000 per farm, and higher payments for designated Natura SAC and SPA lands. Interested farmers (including young farmers / new entrants post 2022) cannot be left without an agri-environment scheme until post-2027 CAP Programme.
• Strong measures to support committed young farmers across all schemes.
De Minimis State Aid thresholds
Under EU rules, Member States are generally prohibited from providing state aid or 100% nationally financed supports to farms/businesses without Commission approval, so as to avoid distorting competition. However, under the de minimis rule, small amounts of state aid can be paid without Commission approval. For farmers/primary food producers, the limit is €20,000 over three years currently.
These 100% nationally financed supports are being increasingly utilised for targeted interventions at farm level, whether relating to improved access to finance; mitigating on-farm challenges and/or the provision of strategically important supports.
In the face of continued and more complex operating markets, it is likely that farmers, particularly those in most vulnerable sectors, will require similar targeted fiscal supports in the years ahead to offer business continuity during these volatile periods.
To propose;
- Increase the ceiling of aid in the agricultural sector per single undertaking to €50,000 over the course of three years to better account for inflation; the increased operational risks endured by farmers, and likely requirement for increased nationally financed interventions to mitigate.
- Full ‘De Minimis' should not be allocated at the point of legal acceptance in Year 1 of a multi-annual scheme, but instead distributed out over the lifetime of the scheme.
- Article 3(7) of COMMISSION REGULATION (EU) No 1408/2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union should be amended. An undertaking should be entitled to the amount of funds (at least) that would bring them from existing position to the threshold amount rather than dismissing the application entirely where the threshold is exceeded.
- The Government should use opportunities presented through CAP Strategic Plan (CSP) amendments to build part / all of existing nationally funded schemes into CSP (keep funding allocations). This would remove such schemes from state-aid calculations and give greater financial security to farmers.
Producer organisations (POs)
Under the EU Commission CAP proposals there are a number of opportunities for Member States to select specific sectoral interventions in their strategic plans. These are vital for vulnerable sectors. POs provide producers with a mechanism to group supply and thereby strengthen their position in the market. There are opportunities for all sectors to be supported in this market structure.
To Propose
• The next CAP must continue to support POs for all sectors.
• The costs, rules, regulations and administrative burden, including reporting and inspections of POs, be simplified further to encourage uptake.
• Additional funding to support establishment and ongoing running costs is required.
• Additional protections are required against the unfair treatment of POs by buyers.
• Potato producers must qualify under the EU Fruit and Vegetable PO scheme.
Trade Deals
That the EU must not agree any trade deal which
- Further compromises the viability of EU agriculture sectors
- Sets a double standard in the market and undermines the quality and standards of EU food.
- Trade agreements must include a sustainability requirement, the implementation must be monitored, and the sustainability work done recognised to ensure reciprocity in farm production standards and a level playing field to ensure fair trade.
To seek support for IFA position on the potential simplification package.
To forge alliances with our French counterparts and re-affirmed the importance of securing the Common Agricultural Policy (CAP) budget in the first place and then looking for the distribution of that budget in a way that food production and farmers are supported.
Barry Cowen
MEP (European Parliament)
Billy Kelleher
MEP (European Parliament)
Ciarán Cuffe
MEP (European Parliament)
Ciaran Mullooly
MEP (European Parliament)
Cynthia Ní Mhurchú
MEP (European Parliament)
Grace O'Sullivan
MEP (European Parliament)
Luke Ming Flanagan
MEP (European Parliament)
Maria Walsh
MEP (European Parliament)
Nina Carberry
MEP (European Parliament)
Peter Burke
Minister (Department of Enterprise, Trade and Employment)
Sean Kelly
MEP (European Parliament)
Brendan Gleeson
Secretary General (Department of Agriculture, Food and the Marine)
Martin Heydon
Minister (Department of Agriculture, Food and the Marine)
Barry Cassidy
Special Adviser (Department of Agriculture, Food and the Marine)