Relevant Matter
Legislation
Public Policy Area
EU Affairs
Period
1 Sep, 2025 to 31 Dec, 2025
Specific Details
Common Agricultural Policy (CAP) Simplification
Intended results
To highlight that, in the new mandate of the Commission starting in 2024, there has been a significant focus on simplification of bureaucracy and it is only right that this focus also extends to agricultural policy, especially the CAP which has wide reaching impacts on how Irish farmers manage their land on a day-to-day basis.
To point out that the new CAP began on January 1st 2023 and caused significant delays in the receipt of farm payments coupled with reduced net benefits at farm level due to the application of the ‘income foregone cost incurred' payment model. The principle of subsidiarity underpins the CAP Strategic Plan (CSP) model which was aimed at increasing the level of autonomy that Member States had over the design of their CSP.
While this has been true for certain elements of the CAP, the application of rigid principles such as those in GAEC 2 on peatlands and wetlands disproportionally impact Irish farmers relative to mainland European farmers
To emphasise that the current implementation of GAEC 7 on Crop Rotation and Diversification is forcing Irish tillage farmers out of business, which is a direct barrier to expanding the area under tillage which is government policy. Farmers which are operating on tillage areas below 30ha are reducing their cropped area due to the compulsory requirement to grow 2-3 crops as per GAEC 7.
That there are certain amendments which are to be voted on this Wednesday October 8th which could significantly improve the implementation of the CAP in Ireland. The priority amendments for IFA are listed below
23 Art 1.1.5 Reg 2021/2115 Art 13.1.3 - Propose farmers in conversion / part of holding organic shall be deemed compliant with GAEC1,3,4,5,6,7. Propose also those in SAC/SPA are deemed compliant with GAEC1-7 for part of holding situated in these sites. MS who have additional GAEC established by national law may extend above-mentioned list of compliance with their specific GAECs. Decisions shall be notified to the Commission
24 Art 1.1.5 Reg 2021/2115 Art 13.4a New text Farmers whose entire holding is less 50 ha shall be deemed to comply with the three-crop rule per GAEC standard 7 listed in Annex III of Regulation (EU) 2018/848. The 2-crop rule shall be removed entirely.
31 Art 1.1.10b Reg 2021/2115 Art 31.5.3 Grammatical change – ‘shall' for ‘may decide to' [re exemption to GAEC2]
80 Art 1.1.5 Reg 2021/2115 Art 13.1. Farmers whose entire or part of their holding is certified for, or in conversion to, organic farming within the meaning of Regulation (EU) 2018/848 of the European Parliament and of the Council* shall be deemed to comply with GAEC standards 1, 3, 4, 5, 6 and 7 listed in Annex III to this Regulation for the certified or in conversion part of their holding. Natura 2000 sites are to be automatically deemed compliant with GAEC standards 2 to 7, provided that con
Natura 2000 sites are to be automatically deemed compliant with GAEC standards 2 to 7, provided that conservation measures which cover GAEC 2 to 7 per designated protected areas management plan are in place and implemented in full on the entirety of the respective area. Member States that have additional GAECs established by their respective national law may decide to extend the above-mentioned list of compliance with their specific GAECs. Such decisions shall be notified to the Commission.
87 Art 1.1.5 Reg 2021/2115 Art 13.1.5 (new) The implementation of the mandatory condition related to the Basic Income Support on wetlands and peatlands (GAEC standard 2) shall be suspended for all farmers, irrespective of farm size, production type or location due to its administrative complexity and the lack of clear operational guidance.
To seek the support of the Irish MEPs for these priorities at the vote in the European Parliament in Strasbourg on the 8th October.
To note with interest that Ireland was not among the signatories of the joint statement tabled at the Special Committee on Agriculture (SCA) on October 6th, demanding that the CAP provisions across the legislative texts be transferred into the same legal act to ensure the commonality of rules.
To emphasise that such a proposal would present CAP in a more coherent, integrated & manageable way, supporting greater understanding, negotiation and subsequent compliance on the part of both beneficiaries and paying agencies alike.
To seek clarification or reasoning why the Department of Agriculture, Food and the Marine (DAFM) chose not to support the proposal as presented.
To highlight that, on the 8th of October last in Strasbourg a series of amendments were passed by the EU Parliament regarding CAP regulations and the conditionality system. To note in particular Amendment 23 which was passed by MEPs
To stress that, given the principles, rules and governance structures underpinning existing practices on Organic farming systems, and those operating on designated sites in Ireland, such holdings, or part thereof as relevant, should be deemed to comply with GAEC standards 1, 3, 4, 5, 6 and 7 and GAEC standards 1 to 7 respectively.
To emphasise that, to afford greater flexibility, reduce complexity, administration and duplication of effort, on part of the farmer and paying agency, it is vitally important that amendment 23 is carried and supported by Ireland right through the trilogue process and implemented as quickly as possible by DAFM.
Name of person primarily responsible for lobbying on this activity
Francie Gorman IFA President, John Curran IFA Rural Development Chair, Liam MacHale IFA Director of European Affairs, Shane Whelan IFA Senior Policy Executive, Liam Delaney IFA
Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?)
No
Did you manage or direct a grassroots campaign?
No
Was this lobbying done on behalf of a client?
No
Lobbying activity
The following activities occurred for this specific Subject Matter Area.
Designated public officials lobbied
The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them.
As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.
Aodhán Ó Ríordáin
MEP (European Parliament)
Barry Andrews
MEP (European Parliament)
Barry Cowen
MEP (European Parliament)
Billy Kelleher
MEP (European Parliament)
Ciaran Mullooly
MEP (European Parliament)
Cynthia Ní Mhurchú
MEP (European Parliament)
Kathleen Funchion
MEP (European Parliament)
Luke Ming Flanagan
MEP (European Parliament)
Lynn Boylan
MEP (European Parliament)
Maria Walsh
MEP (European Parliament)
Martin Heydon
Minister (Department of Agriculture, Food and the Marine)
Michael McNamara
MEP (European Parliament)
Nina Carberry
MEP (European Parliament)
Regina Doherty
MEP (European Parliament)
Sean Kelly
MEP (European Parliament)
William Aird
TD (Dáil Éireann, the Oireachtas)
Sinead McPhilips
Assistant Secretary (Department of Agriculture, Food and the Marine)