Evolution or revolution: assessing the Commission's CAP 2028-2034 proposal 17 Secondly, the ‘General Allocation’ element in the NRP Fund, which collects the current shared management funds, has been assigned an additional objective: to finance infrastructure to facilitate military mobility. This will place greater demands on the budgets of some countries compared to others, depending on their geographical location. There is also a possibility for Member States to transfer resources from the General Allocation to the European Competitiveness Fund. A third constraint on funding for the CAP is the requirement in the NRP Regulation that Member States must freeze 25% of their General Allocation (excluding the CAP ring-fenced amount) as a flexibility amount. In the early years of the programming period, this amount is reserved to deal with natural catastrophes. At the mid-term review in 2031, Member States will be allowed to programme the unspent funds, including on new challenges that may have emerged since the National Plans were designed. Some funds must still be retained to address natural disasters which, if still unspent, can only be released after June 2033. While these funds are frozen in this way, they will not be available to top up the funding of CAP interventions. The Commission has emphasised that a corollary of a larger budget is agreement on new own resources if national contributions are to be held stable. However, there seems to be little appetite among Member States to agree on new own resources (which would not only have to be agreed unanimously by Heads of State and Government at the European Council but also approved by all national parliaments). Several Member States have already indicated that they are seeking a reduction in the proposed MFF budget. If cuts are made, even whether the minimum ringfenced amount proposed by the Commission can be maintained will be up for debate. Significant revisions to well-known CAP tools Direct payments. The Commission's commitment on direct payments was to make them fairer and more targeted. Payments should be made to farmers who are actively engaged in food production and contributing to food security. If Member States wish, payments can also be made to parttime farmers who have significant agricultural activity. There are five main innovations with respect to direct payments. First, the existing DP schemes (BISS, CRISS, young farmers) are merged into a new payment called DABIS, the Degressive Area-Based Income Support. Member States will be obliged to differentiate these payments according to objective income indicators. The CAP Regulation gives a nonexhaustive list including small farms, women farmers, farms in areas of natural constraints, and farms combining crops and livestock. The payment can be made either based on area or as a lump sum (the Commission gives the example where female farmers might receive a lump sum top up on their standard area-based payment). In its Strategy for Generational Renewal in Agriculture in October 2025, the Commission recommended that Member States dedicate at least 6% of their agriculture ring-fenced amounts to generational renewal. 5 Second, the DABIS payment will be tiered (degressivity) and capped at a ceiling of €100,000. This will be mandatory for Member States and no deduction for labour costs will be permitted. Thirdly, farmers receiving a national pension will no longer be eligible for the DABIS payment, as part of a policy to encourage the release of land for a new generation of younger farmers. Fourth, it will now be mandatory for Member States to introduce a small farmer payment with a maximum limit of €3,000. Small farms will be exempt from farm stewardship requirements (apart from social conditionality) and will also be allowed to receive this payment in addition to any pension to which they are entitled. Fifth, it will be obligatory for Member States to provide coupled support for sectors undergoing difficulties and important for environmental or socio-economic reasons, and the maximum ceiling has been raised. For livestock payments, Member States must take into account environmental impacts, including by setting a maximum livestock density in nitrate vulnerable zones. A feature of the DABIS payment is that it is the only ringfenced instrument within CAP income support. The Commission proposes that the average payment per hectare in Member States should vary between a minimum of €130 per hectare and a maximum of €240 per hectare. While giving additional flexibility to Member States, this wide range risks fuelling antagonism among farmers competing in a single market. Green architecture. The Commission’s proposals to modify the green architecture of the CAP reflect its commitment in its Vision paper to orient the future CAP away from 5 Commission, Strategy for generational renewal in agriculture, COM(2025) 872.
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