CAP Simplification

The EU Agriculture Commissioner, Phil Hogan, has set out his plans for simplifying the Common Agricultural Policy, and especially the Basic Payment Scheme. 

The first announcement was for ‘preventative preliminary checks’.  Member States would have the option to make initial checks to a BPS application to identify any problems; the applicant could then make corrections, without penalty, up to 35 days after the submission deadline.  Although this measure would put many minds at rest about ‘little’ mistakes in the claim it would be a big task for the adminstrators to complete the checks, inform claimants and still give time to make the changes all within 35 days. However for those administrations with a successfully working online system the checks many be able to be built in and automatically inform applicants of any errors.  If the option is available it may encourage claimants to submit their form as early as possible to allow more time for checks to be made and changes submitted.

A number of measures are being suggested to reduced the number of spot checks.  Where Member States have overall error rates below 2% and the LPIS (Land Parcel Information System) has been updated within the last three years, spot check requirements for certain schemes, will be reduced from 5% to 1%.  The efficiency of selecting samples to spot check should reduce the need for multiple checks to be made on the same unit.  Reducing the number of checks will be welcomed by farmers and administrations alike (particularly in light of budget cuts – see previous article) but full details of the rules around reducing checks have not been published. It is possible the DEFRA and other UK administrations will not meet the strict requirements. Phil Hogan also started his will only be possible for certain schemes, this may not include BPS at all but may be more directed to Pillar 2 schemes.

Farmers will also have further possibilities to ‘modify their declaration’ regarding the use of parcelsfor Greening, this will allow some flexibility for changes that take place during the cropping year. It seems this is an expansion of what was permitted under the 2015 rules where farmers who had ‘missing EFA’ could use other EFA features to satisfy that element.  These new rules may include allowing changes in both the Crop Diversification and EFA elements of Greening.

The changes above are expected to be adopted by the EU Commission in mid-December and be available for the 2016 claim year.

Further simplification measures are also being discussed.  This includes more flexibility to target support.  A number of Member States had problems implementing the Young Farmers Scheme, particularly where a young farmer and another farmer have joint control of the business.  Rule changes will allow national administrations to have some discretion in these situations. There are also a number of simplification measures relating to market measures such as private storage and intervention.

The Commission is also aiming to reduce the current number of regulations down from around 200 to 40 Delegated and Implementing Regulations.

A number of reviews are to be conducted with a view to implement further changes;

• A review of adminstrative penalties is to be conducted looking at ‘appropriate penalty levels’.
• A package of changes to Delegated/Implementing Acts in relation to Greening will be published before summer 2016 to be in place by the 2017 claim year.
• Measures to simplify access to financial instruments such as access to affordable finance to young farmers
• High level review of Rural Development Programmes to simplify and reduce the administrative burden for Member States and farmers/beneficiaries. The may include allowing flexibility to modify RDP’s more than once a year.

The reopening on the Basic Acts, those which sit above the Delegated and Implementing Acts, will also be considered if deemed necessary for the simplification process.  This may be required following the EFA review or if the Active Farmer definition requires amending.