28 CADERNOS DE ANÁLISE E PROSPETIVA CULTIVAR N.º 34 O futuro da Política Agrícola Comum tions towards incentives.6 It argues that it is not lowering its ambitions to support farmers to shift towards more sustainable practices, but it is reducing the burden of regulation and moving more to the provision of incentives. There is indeed strong legal language in the proposed Regulations, for example in Article 4 of the CAP Regulation that requires Member States to address at least six environmental and climate priorities in the CAP chapter of the national Plans. There are also positive innovations. These include the merging of eco-schemes and agri-environment measures into a single intervention for agri-environment-climate actions. This will make it easier for Member States to co-ordinate short-term and longer-term actions. There will be greater flexibility for Member States in setting payment rates, the introduction of a new transition payment to de-risk the transition to more sustainable farming models, and an obligation on Member States to provide support for extensive livestock production systems and areas with nitrate surplus. Conditionality associated with eligibility for direct payments will be replaced by farm stewardship. Farmers will still be required to observe the same set of Statutory Management Requirements, and social conditionality is integrated into farm stewardship. The major change is that Good Agricultural and Environmental Conditions will be substituted by protective practices to be defined by Member States. These have broadly the same objectives as conditionality in the current period following the various simplification measures that have been adopted. However, the language around protective practices is more general and less directive, giving Member States greater flexibility in their design. For example, whereas GAEC 4 requires the establishment of buffer strips along water courses which should, as a general rule, respect a minimum width of 3 metres without using pesticides and fertilisers, the relevant protective practice merely prescribes that Member States must establish standards that protect water courses against pollution and run-off, leaving it up to Member States what these standards should be. The biggest change is that Member States will, in future, be able to compensate farmers to the cost of complying with these mandatory requirements. In the current CAP, the practices specified in conditionality form a baseline. Member States can only pay farmers for voluntary environmental and climate commitments, either through ecoschemes or Pillar 2 measures, that go beyond this baseline. This change is in line with the Commission’s declared aim to rely more on incentives, although the practices them6 Commission, A Vision for Agriculture and Food; Shaping together an attractive farming and agri-food sector for future generations, COM(2025) 75. selves will remain mandatory for those farmers in receipt of direct payments. Further, Member States have greater scope to provide exemptions and derogations in specified circumstances. Controls in future will not apply to holdings that are smaller than 10 hectares in size. The main fear is that, despite the high ambitions for the green architecture in the legal texts, the money available to support farmers in moving towards more sustainable farming systems, including carbon farming, will likely be severely reduced. This is partly because there is no ringfenced budget for agri-environment-climate actions as in the current CAP. As part of the budget tracking mechanism, Member States are required to ensure that at least 43% of the NRP Plan budget has a positive impact on climate action or the environment, using a system of EU coefficients that defines the contribution of each intervention towards these objectives. But this will be a very weak incentive to allocate CAP funding to ambitious climate and environmental measures, given that the coefficient attached to direct payments (due to the farm stewardship requirements) is already 40%. Also, the new provision that member states can compensate farmers for the cost of engaging in mandatory protective practices will no doubt be welcomed by farmers, but to the extent that Member States pay farmers for these practices, this will further reduce the funding available for voluntary actions with greater ambition. The lack of ring-fencing is more troubling because of the incentives Member States will have to limit spending on agri-environment-climate actions. Within the ring-fenced budget for CAP income support, spending on direct payment interventions (DABIS, coupled support, cotton, small farmer payment) is wholly financed from the EU budget and does not require national contributions. All other CAP expenditure, including agri-environment-climate actions, will require a national contribution of 30%. If Member States wish to top up their minimum CAP ringfenced amount from the unearmarked amount in their NRP Plan budget, any such expenditure must be co-financed by national contributions according to the appropriate minimum rate for the region where the expenditure takes place. This can be as low as 15% for less developed regions but as high as 60% for more developed regions. There will be a requirement to show spending to address the agri-environment-climate objectives set down in the legal texts in order for the national Plans to be approved. Still, for
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