Interim evaluation of the Common Agricultural Policy (CAP) within the 2021–2027 budget

The potential of the CAP to address social injustice remains underutilised by Member States. Working in European agriculture is dangerous. The number of fatal accidents in the agriculture sector is deplorably high. Estimates shows that around 500 fatal accidents occur in the agriculture sector per year. Agriculture also accounts for over 150,000 non-fatal accidents annually.

Thank you for the opportunity to contribute to this important public consultation on the Mid-term Review of CAP 2023-2027. The Irish Farmers Association (IFA) is Irelands largest farming organisation with approximately 77,000 members in 940 branches nationwide.

ELO welcomes the Commissions mid-term evaluation and the opportunity to contribute with evidence gathered through direct consultations with farmers across Member States. This submission focuses on the practical effects of Regulation (EU) 2024/1468 and the broader simplification agenda on farm-level administrative burden. Please find enclosed the detailed feedback.

The CAP remains highly relevant in a context defined by climate disruption, geopolitical instability and repeated market shocks. Therefore, it should respond to these challenges through smart, strategic support for resilient farming systems. The CAP must become more protein-focused and more resilience-oriented.

This contribution addresses the role of institutional coherence in enabling the digital transformation of European agriculture under the CAP. It argues that fragmentation across CAP instruments, EU data legislation, and national implementation creates coordination, transaction, and switching costs (governance penalty) that affect technology adoption.

IFOAM Organics Europe is the umbrella organization for organic food and farming, representing over 200 members all over Europe, all along the organic value chain, from producers to processors, certification bodies, distributors and research centers.

ASINCA, as the most representative association of the industrial sector in the Canary Islands, is participating in this consultation to defend the interests of the Canary Islands industries benefiting from POSEI (Programme of Options Specifically Relating to Remoteness and Insularity) and SSA (Specific Supply Arrangements), which are essential instruments for compensating for the permanent structural disadvantages…

Filed in Spanish · English published by the European Commission

The District of the Three Waters of Milan (Dinamo) is a unique example of an agricultural district, characterised by the adoption of principles of eco-sustainable agriculture and a commitment to maintaining environmental quality, through the promotion of an agricultural model based on virtuous practices.

Filed in Italian · English published by the European Commission

Estonia considers it necessary to make the following observations on the implementation of the CAP 2023-2027, which are also important to take into account when designing the CAP for the next period: Experience so far shows the need to adapt the audit approach in order to achieve the objectives of CAP simplification.

Filed in Estonian · English published by the European Commission

The common agricultural policy (CAP) is a cornerstone of the EU: since 1962, it has supported farmers and ensured Europe’s food security. The mid-term evaluation will assess the first results of the CAP 2023-2027. It will focus on objectives linked to the common EU targets for the social, environmental and economic sustainability of agriculture and rural areas. With control over actual versus fictitious production.

Filed in Italian · English published by the European Commission

The german umbrella organisation for organic food producers, processors, and traders (BÖLW) would like to thank you for the opportunity to comment on the mid-term review of the CAP 20232027. The current green architecture of the CAP, with full EU funding for eco schemes and a clear environmental budget, has already led to tangible environmental improvements and is well received by both farms and the administration.

Filed in German · English published by the European Commission

Research evidence from a range of recent projects at Ecologic Institute shows that the Common Agricultural Policy (CAP) is only partially effective in delivering environmental and climate objectives in practice. This underperformance is not due to a lack of available instruments, but to persistent weaknesses in the delivery model, which limit the translation of policy objectives into measurable outcomes.

World Animal Protection Sweden welcomes the opportunity to contribute to the European Commissions Call for Evidence on the midterm evaluation of the Common Agricultural Policy (CAP) 20232027. Evidence from Sweden: Design and Performance of Animal Welfare Payment: Sweden has long applied CAP animal welfare payments exclusively to practices that exceed baseline legal requirements.

The CAP, as the EUs main tool shaping land use, has a key role in addressing environmental and climate challenges. This is where it can bring clear EU added value, requiring coordinated EU action to protect shared natural resources and meet common environmental goals. It is also essential for the long-term viability and resilience of farming systems.

Hikvision welcomes the opportunity to contribute to the European Commission's mid-term evaluation of the Common Agricultural Policy (CAP). We strongly support continued CAP investment in agricultural digitalisation and believe that well-designed support can help European farmers improve productivity, sustainability and long-term resilience. Please find our observations and recommendations in the attached document.

The Provence-Alpes-Côte d’Azur region (South) recognises the Common Agricultural Policy (CAP) as a strategic European policy. It reaffirms its commitment to an effective CAP that is readable and fully adapted to the realities of national and regional agriculture.

Filed in French · English published by the European Commission

AGRI Ouest Europe considers it necessary to draw up a review of the CAP 2023-2027 at this stage of its implementation, as well as to express certain wishes and concerns with regard to the financing proposals for agriculture for the period 2028-2034. Please find our response to this call for evidence attached. We remain at your disposal for further consideration of the points raised therein.

Filed in French · English published by the European Commission

Euromontana is the European multi-stakeholder network for mountain areas. Our mission is to promote living mountains, integrated sustainable development and quality of life in the mountains. Euromontana welcomes the European Commissions consultation on the Common Agricultural Policy (CAP) mid-term evaluation for 2023-2027.

CAP 2023-2027 mid-term evaluation: Need for greater scrutiny on cage-free transition support While several reports (e.g. European Court of Auditors 2024, Birdlife 2025) have already established that the CAP 2023-2027 failed to deliver significant improvements for the environment, Compassion in World Farming would like to focus our contribution on the CAP as an instrument to support the transition towards cage-free…

--See document attached for full EUSTAFOR input-- The current CAP already represents a significant shift towards a performance-based delivery model, granting Member States greater flexibility in designing and implementing interventions.

The National Society for the Protection of Birds submits critical comments on the implementation of the provisions of the Polish CAP Strategic Plan 20232027 with regard to selected standards and eco-schemes and indicator R.34.

Filed in Polish · English published by the European Commission

CEVI, the European Confederation of Independent Vignerons, is the only organisation that represents and defends the interests of Independent Vignerons at European level. Independent Vignerons are entrepreneurs running their micro, small and medium-sized enterprises (SMEs), which are often family-run.

Filed in French · English published by the European Commission

Deutsche Umwelthilfe e.V. (DUH) is grateful for the opportunity to comment on the mid-term review of the Common Agricultural Policy (CAP) 2023-2027. The DUH notes that, in its current funding period, the CAP does not sufficiently meet its own objectives or key societal expectations in the area of climate, environmental and animal welfare.

Filed in German · English published by the European Commission

We would like to respond to this call for evidence in relation to CAP payments that are used for the breeding of bulls and cows intended for bullfighting and related events. EU citizens care about animals and their welfare. When it comes to animal welfare in relation to CAP-payments it is striking that these payments are still used by breeders of bulls and cows intended for bullfighting and related events.

As an environmental NGO, the EEB considers that the recent CAP changes appear as failing to properly address farmers concerns while weakening environmental safeguards. The simplification processes lacked transparency and were pushed through without sufficient consultation or evidence, resulting in a more uncertain and less effective framework overall.

Thank you for the opportunity to contribute, please find FoodDrinkEuropes feedback attached. Our contribution addresses Question 2 (EU added value of the CAP) and Question 3 (continued relevance of the CAP in addressing current and emerging challenges), reflecting the perspective of the EU food and drink manufacturing sector as a key stakeholder in the agri-food value chain.

1. Administrative burden and simplification The introduction of the nationally uniform, 100 % EU-funded organic schemes is expressly to be welcomed. In practice, however, the combination of these eco-schemes with nationally and regionally co-financed agriculture, environment and climate measures (AECM, EAFRD, organic premium) leads to considerable complexity.

Filed in German · English published by the European Commission

Intermediate results from the MODEMA project: Development of a nationwide model and demonstration network for agroforestry in Germany - www.defaf.de/modema. Agroforestry is a key measure for multifunctional agriculture and the CAP should now move forward.

Filed in German · English published by the European Commission

CAP reform is needed to accelerate emissions reduction and climate adaptation in the agricultural sector Agricultural emissions and vulnerability to climate hazards varies significantly between MS. The CAP can enable cross-border coordination and targeting of support where most needed.

Save Soil welcomes the European Unions continued commitment to supporting farmers, ensuring food security, and strengthening environmental and climate action through the Common Agricultural Policy (CAP). However, based on early implementation (20232025), the CAP can be more effective in addressing current and emerging challenges, as soil health is not yet operationalised as a core outcome.

# # simplification # # 2024 relaxed or made voluntary several GAECs. These results are ambiguous: a study commissioned by the EC (27000 participants) concludes that up to 60 % of the administrative burden is due to MS implementation choices [1]. European simplification is not enough to reduce the perceived burden and subsidiarity contributes to the overload: ambitious harmonisation would be more convincing.

Filed in French · English published by the European Commission

With CAP accounting for of the EU budget, its ambition to create a sustainable, high-quality food production across member states is a unique opportunity to strengthen antimicrobial stewardship in farming. Globally, around 70% of all antibiotics sold are used in food-producing animals, and trends suggest continued growth by 2030.

The evidence compiled by the LIFE EUROBUSTARD project across Spain, France, Austria, Portugal, Romania and Hungary indicates that the current CAP (20232027) provides relevant instruments for biodiversity conservation, but its design and implementation are insufficient to halt the decline of steppe bird populations at EU scale.

As an organization dedicated to community empowerment and vocational excellence, we believe that the CAP mid-term evaluation should further emphasize vocational training innovation. Supporting small-scale producers is most effective when coupled with advanced skills in agri-food processing and international quality standards.

Animal protection mid-term evaluation of CAP 2023-2027: The EU’s agricultural support scheme is a key policy instrument for Europe’s food production, but in its current form it does not deliver enough on the public goods that society needs and citizens expect.

Filed in Danish · English published by the European Commission

The BEATLES Horizon Europe project, focused on enabling behavioural change towards climate-smart agriculture, welcomes the European Commissions mid-term evaluation of the Common Agricultural Policy (CAP) as a key opportunity to assess not only implementation progress but also the real effectiveness of CAP instruments in driving sustainable transitions on the ground.

The German Farmers’ Association (DBV) is commenting on the mid-term evaluation of the CAP 2023-2027. The CAP influences economic stability, has an impact on the EU’s internal market, targets environmental performance and the sustainability of farms. The experience from 2023-2025 clearly shows that the CAP remains a key pillar of European agriculture.

Filed in German · English published by the European Commission

CAP 2023-2027 mid-term evaluation: Animal welfare instruments are insufficiently used The contribution focuses on the continued relevance of the CAP in terms of addressing current needs. More than one million citizens have called on the Commission to end the use of cages in animal farming and there is an urgent need to update the animal welfare legislation in line with citizens expectations and scientific evidence.

AnimalhealthEurope is the association representing the manufacturers of veterinary medicines, vaccines and other animal health products. AnimalhealthEuropes membership covers 90% of the European market for animal health products. Our membership includes both animal health companies and national associations, representing both innovators and generics alike, as well as large, medium-sized and small companies.

My feedback focuses on agri-environmental policy instruments within the CAP framework, specifically AECMs and eco-schemes, and builds an argument grounded in a governance perspective, situating these instruments within broader CAP decision-making. Evidence is based on four years of doctoral research and related publications, and substantiated by other publications within the broader literature (see attached).

Since the 2024 CAP simplification package, some administrative burdens have eased (notably digital tools, clearer eco-scheme guidance, and faster payments in certain Member States), but many new complexities emerged. Farmers and administrations report at least 16 areas where implementation has become harder, particularly due to uneven national delivery models, stricter conditionality, and fragmented digital systems.

The Common Agricultural Policy (CAP) remains a strategic pillar for ensuring food security, rural cohesion, and the competitiveness of European agri-food value chains. From the perspective of the General Council of Catalan Chambers of Commerce, representing a highly export-oriented agri-food ecosystem, the mid-term evaluation of the 2023-2027 CAP should focus on five key dimensions: 1.