CELEX:52025AE1558: Opinion of the European Economic and Social Committee – Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2021/2115 as regards the conditionality system, types of intervention in the form of direct payment, types of intervention in certain sectors and rural development and annual performance reports and Regulation (EU) 2021/2116 as regards data and interoperability governance, suspensions of payments annual performance clearance and controls and penalties (COM(2025) 236 final – 2025/0236 COD)

European flag Official Journal of the European Union EN C series
C/2026/38 16.1.2026
Rapporteur: John COMER
Co‑rapporteur: Arnold PUECH d’ALISSAC
Advisors Frank ALLEN (to the rapporteur) – Roch‑Marie STERN (to the co‑rapporteur)
Legislative procedure EU Law Tracker
Referral European Parliament, 16.6.2025; Council of the European Union, 25.6.2025
Legal basis Articles 43(2) and 304 of the Treaty on the Functioning of the European Union
Commission document COM(2025) 236 final – 2025/0236 COD
Relevant SDGs SDG 8, SDG 10, SDG 12, SDG 15
Section responsible Agriculture, Rural Development and the Environment
Adopted in section 8.9.2025
Adopted at plenary 18.9.2025
Plenary session No 599
Outcome of vote 120/0/1

1. RECOMMENDATIONS

  1. Increased and improved digitalisation should be a key strategy for achieving simplification of the CAP, by enabling the use of digital tools for data collection, monitoring and payment processing. Member States must prepare a specific plan for enhancing digitalisation and further streamlining and standardising IACS‑based procedures, improving user‑friendliness, interoperability and services to farmers.
  2. Digitalisation can be a burden on farmers who lack digital skills and equipment, especially older farmers and those in remote locations. Member States need to actively promote and support farmer digital‑skill training, provide financial support for up‑skilling, and establish a dedicated helpline. Efforts must eliminate the need for private consultants.
  3. Administrative burden reduction: each CAP Strategic Plan should contain a specific plan for shortening application forms, using pre‑populated forms and the most up‑to‑date digital technology to access relevant data.
  4. Support for new farmers: First‑time farmers setting up an agricultural holding as head of the holding should receive the same investment support terms as young farmers, provided they are active farmers.
  5. Extended support for groups of young farmers: If a farming company, holding or group incorporates two or more young farmers in different years, it should be eligible for more than five years of complementary income support.
  6. Payment ceiling for small farmers: The annual payment for small farmers should not exceed EUR 5 000 (index‑linked) where payments are made as a lump sum or per‑hectare amounts replacing direct payments. Conditionality controls and penalties should not apply to these payments.
  7. Reduce on‑the‑spot inspections: The number of field inspections should be significantly reduced by increased use of modern technology while protecting the Union’s financial interests.
  8. Correctable applications: Member States may allow aid applications and payment claims to be corrected after submission, without affecting the right to aid, provided corrections are made in good faith and before the applicant is notified of an on‑the‑spot check or before a decision is taken.
  9. Non‑discrimination in risk‑management participation: Farmers who, due to unforeseen circumstances, have been unable to participate in a risk‑management tool system should not receive a lower compensatory payment rate.
  10. Emergency funding: In exceptional circumstances where a natural disaster or catastrophic event exceeds available funds, the Commission – together with the Member State – must provide extra emergency funding; crisis payments must not reduce allocations for basic income support.
  11. Alternative payment systems: Member States should have discretion to apply an alternative payment system instead of per‑hectare payments for area‑specific disadvantages imposed by mandatory requirements.
  12. GAEC revision: The Good Agricultural and Environmental Conditions (GAECs) need a full evaluation and revision to be farmer‑friendly and to support EU food security while ensuring good environmental practice.
  13. Irrigation investment support: Support for irrigation investments should not be dependent on the interpretation of ‘less than good’ water‑body status, to avoid distortions between Member States and regions.

2. EXPLANATORY NOTES

2.1. Remote sensing and digital databases

Remote sensing and integration of digital databases can improve monitoring and simplify processes. Satellite‑based observation systems combined with AI can have a major impact on simplification. Data confidentiality must be protected and farmers should retain control of their data. Member States must modernise digital infrastructure to reduce administrative burden.

2.2. Digitalisation burden risk

Greater digitalisation could create a ‘two‑speed’ agriculture, leaving some farmers behind. Digital skills must be updated, especially for those lacking them. Simplified, shortened application forms are essential. Funding should support knowledge sharing, communication and advice for farmers.

2.3. Generational renewal

The number of farms and farmers is declining; half are over 55. Policies must make farming attractive for new and young farmers to ensure generational renewal.

2.4. Support for small farmers

Small farms have been disappearing; a mix of farm sizes is needed for a socially cohesive rural community. Special support for small farmers is essential.

2.5. Application correction

The CAP should be user‑friendly; mistakes made in good faith must be correctable without penalty, with a helpline available.

2.6. Crisis payments and food security

In cases of natural disasters or catastrophic events, compensation must be fair and not reduce basic income support. Maintaining food security is vital, especially under climate change.

2.7. GAEC implementation

GAECs were created in 2003, first applied in 2005. By 2025, GAEC standards vary between Member States, leading to unequal requirements and implementation dates.

2.8. Cross‑compliance compliance rate

The European Court of Auditors reports around 99 % compliance with cross‑compliance rules.

2.9. Eco‑schemes uptake

In France, 92 % of farmers subscribe to eco‑schemes, which often go beyond GAEC requirements.

2.10. GAEC simplifications 2024‑2025

Simplifications of GAECs 1, 7 and 8 have rendered some standards inoperative or non‑binding.

2.11. GAEC complexity

Complex GAECs lead to calculation errors, delays, and additional costs for farmers and administrations.

2.12. New GAEC for wetlands

GAEC 2 on wetlands and peatlands is new (2024‑2025) and its impact is not yet known.

2.13. Irrigation and water scarcity

In water‑scarce areas, subsidies on storage are essential for irrigation; irrigation support must respect other ecosystem needs.

3. PROPOSED AMENDMENTS TO THE LEGISLATIVE PROPOSAL OF THE EUROPEAN COMMISSION

Amendment 1 (linked to recommendation 1.1) – Add to Article 6:

“4. Increased digitalisation must be a key strategy for achieving simplification of the CAP by enabling the use of digital tools for data collection, monitoring and payment processing.” Reason: To make administration easier.

Amendment 2 (linked to recommendation 1.6) – Replace Article 28:

“Payments for small farmers … shall not exceed EUR 5 000 (index‑linked).” Reason: To encourage and maintain smaller farms.

Amendment 3 (linked to recommendation 1.5) – Replace paragraph of Article 30:

“The complementary income support for young farmers shall be granted for a maximum of five years … if a farming company incorporates two or more young farmers in different years, it can be eligible for more than five years.” Reason: To help young farmers and encourage generational renewal.

Amendment 4 (linked to recommendation 1.9) – Add Section 4 to Title III, Chapter II:

“Complementary crisis payments … should not reduce allocations for basic income support.” Reason: Fairness and equity in crisis compensation.

Amendment 5 – Amend Article 70, paragraph (c):

“Where support is granted to agri‑environment‑climate commitments … Member States shall establish a payment per hectare.” Reason: To simplify procedure by removing per‑beehive payments.

Amendment 6 (linked to recommendation 1.11) – Replace paragraph 6 of Article 72:

“Payments under this Article shall be granted annually per hectare. Member States may decide on alternative payment methods if more appropriate to local conditions.” Reason: To make the system as farmer‑friendly as possible.

Amendment 7 (linked to recommendation 1.4) – Replace paragraph 5 of Article 73:

“Support may be granted for investments to comply with new Union requirements for a maximum of 36 months … New farmers setting up for the first time should receive similar terms, provided they are active farmers.” Reason: To ensure support for young and new farmers.\nAmendment 8 (linked to recommendation 1.13) – Delete paragraphs 4, 6 and 7 of Article 74. Reason: The classification of water‑body status is opaque and unequal.

Amendment 9 – Replace first sub‑paragraph of Article 76(5):

“Member States shall ensure support is granted only for losses exceeding at least 20 % of the average annual production or income … For permanent crops, losses may be assessed over up to eight years, excluding the two lowest entries.” Reason: To make crop insurance more efficient and climate‑adapted.

endment 10 (linked to recommendation 1.9)* – Add Article 78a on crisis payments under rural development, with provisions identical to those in Amendment 4. Reason*: To ensure equity and balance in crisis compensatory payments.

Amendment 11 (linked to recommendation 1.10) – Insert Article 96a on maximum financial allocations for crisis payments, including a clause for extra emergency funding when existing funds are insufficient. Reason: To provide necessary emergency in exceptional crises.

Amendment 12 (linked to recommendation 1.3) – Add to Article 107(1):

“(i) a specific plan for reducing the administrative burden of applying for payments by shortening application forms, extensively using pre‑populated forms and the most up‑to‑date digital technology to access the relevant data.” Reason: To reduce administrative burden.

Amendment 13 (linked to recommendation 1.2) – Add to Article 114:

“Digitalisation can be a simplification measure, but its introduction can also be a burden … financial support should be provided as required. A dedicated helpline should be made available … Every effort must be made to eliminate the need for private consultants.” Reason: To ensure digitalisation is farmer‑friendly.

Amendment 14 (linked to recommendation 1.1) – Add Chapter III to Title II on CAP data and interoperability governance, including Article 13a on the authority in charge of data governance and a roadmap emphasizing single‑time data collection and reuse. Reason: To reduce administrative burden and improve user‑friendliness.

Amendment 15 (linked to recommendation 1.8) – Replace paragraph 6 of Article 59:

“Member States may include the possibility for aid applications and payment claims to be corrected after submission, provided the correction is made in good faith and before an on‑the‑spot check or decision is taken.” Reason: To make the system more farmer‑friendly.

Amendment 16 (linked to recommendation 1.7) – Add sub‑paragraph to Article 60:

“If a beneficiary has been selected for an on‑the‑spot check, Member States shall, where possible, not select the same beneficiary for another check in the same year, except when necessary to protect the Union’s financial interests.” Reason: To reduce the number of on‑the‑spot inspections.

Brussels, 18 September 2025.

The President of the European Economic and Social Committee

Oliver RÖPKE


Regulation (EU) 2021/2115 (Official Journal L 435, 6 December 2021)

ELI: http://data.europa.eu/eli/C/2026/38/oj

ISSN 1977-091X (electronic edition)