What Common Agricultural Policy for 2028-2034?

An environmental architecture carrying both risks and opportunities for the sector

The Commission proposes reforming the CAP's environmental architecture, which has been criticized for lacking ambition and effectiveness. Following a logic similar to the current framework, this new model comprises two types of provisions: mandatory rules for farmers receiving European subsidies, and incentive measures that are optional for farmers but mandatory for Member States. However, the architecture of these mechanisms has been modified, granting Member States greater flexibility to design programmes tailored to farmers' needs: choice between annual or multiannual payments; remuneration for services or support for agri-environmental transition; territorial targeting; aid amounts; and practices eligible for support.

Furthermore, whilst environmental measures in the current CAP (2023-2027) benefit from a predefined budget and full European financing for the majority, these provisions are eliminated in the Commission's proposal. Member States must offer green measures to farmers, but the budget allocation remains undefined: it is left to Member States' discretion and must be supplemented by national co-financing of at least 30%. 

The absence of incentives or budgetary and regulatory constraints defined at European level could marginalize agri-environmental measures, particularly given budgetary restrictions and waning political interest in environmental issues. 

Risk management: a sustainability lever? 

In contrast, risk and crisis management is attracting increasing interest from co-legislators, driven by mounting hazards—geopolitical, health, and climatic—facing farmers, whose impacts public authorities must mitigate. Responding to these concerns, the Commission proposes doubling the agricultural reserve budget (renamed the "Unity Safety Net"), used for market crisis response, and provides a flexibility mechanism enabling Member States to assist farmers during climatic and health crises.

The Commission also facilitates enhanced risk management by Member States: it becomes mandatory where no national system exists. Additionally, the draft regulation specifies no particular tools, granting Member States complete flexibility: those wishing to do so can prioritize adaptation measures that strengthen farm resilience to hazards. Conceived from a long-term perspective, this pursuit of resilience could encourage practices beneficial for both climate change mitigation and biodiversity restoration.

However, like agri-environmental and climate actions, these measures lack both a pre-allocated budget and full European financing. Without common guidelines, implementing effective risk management depends entirely on Member States, with no guarantee they will seize the Commission's offered opportunity.

Risk prevention measures, more likely to engage co-legislators in the current political climate than a purely environmental agenda, can only serve as an effective sustainability lever if the common framework is strengthened. This requires, firstly, Member States sharing a common understanding of the most effective measures for anticipating hazards and mitigating their impacts, and secondly, genuine incentives for implementation.

The necessity of European-level safeguards

The Commission's proposed architecture is based on increased subsidiarity: each Member State develops a National and Regional Partnership Plan (NRPP) defining how it will use its pre-allocated European funds. The ambition and common character of this new framework depend almost entirely on the prerogatives the Commission grants itself to guide Member States in developing and monitoring their plans.

These provisions, unpopular with Member States, risk being weakened or eliminated during Council and European Parliament negotiations. Yet without legally defined shared competences, the Commission lacks the "natural authority" to effectively constrain Member States.

Should the Commission's prerogatives be modified during negotiations, the Council and Parliament would need to establish alternative safeguards to ensure both a fair and equitable common market for European farmers and environmental ambition in Member States' action plans. This is particularly critical given the CAP reform proposal's limited detail and the considerable flexibility afforded to Member States and the Commission. Understanding the actors and interests shaping these reform negotiations is therefore essential.

Opening agricultural negotiations to new actors: what are the implications for the next CAP?

The European agricultural sector has historically enjoyed specific political and legislative treatment, partly explaining the CAP's evolutionary continuities. However, the Commission's legislative proposals introduce a new decision-making architecture that opens the negotiation space to non-agricultural actors at both European and national levels.

At European level, adopting a Single Fund—integrating the CAP alongside other shared management policies like cohesion policy—falls under the General Affairs Council's competence. Agricultural experts participate in these negotiations but no longer lead them; they must coordinate with other sectors within the Fund. Agriculture is thus integrated, more substantially than previously, into multi-sectoral negotiations.

At Member State level, the agricultural sector no longer maintains a dedicated national plan but is incorporated into the National and Regional Partnership Plan, whose development involves various ministries and stakeholders. Here too, agricultural interests must be balanced against others, guided by cross-cutting coordination bodies. Given higher national co-financing rates, finance and budget ministries should also gain prominence.

Continuing or departing from the status quo for the CAP 2028-2034?

A period of decisive negotiations for the European agricultural sector's future now begins. Several interdependent processes are unfolding simultaneously across different bodies. This new decision-making architecture, combined with greater Member State subsidiarity and the Commission's concise legislative proposals, heightens uncertainty about the final adopted texts.

A CAP revolution is not guaranteed; indeed, Member States might adopt a framework preserving a policy similar to the current one, albeit at the cost of further weakening its common character and environmental framework. Nevertheless, by proposing new governance and overhauling key CAP mechanisms, including income support, the Commission offers Member States and the European Parliament an opportunity for fundamental CAP reform. The negotiation outcome will depend on power dynamics between various actors, both in Brussels and across national capitals.