2116 as regards data and interoperability governance, suspensions of payments annual performance clearance and controls and penalties - Main contents

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dossier	COM(2025)236 - Amendment of Regulation (EU) 2021/2115 as regards the conditionality system, types of intervention in the form of direct ...
document	COM(2025)236
date	May 14, 2025

(1) In its Communication ‘A Competitiveness Compass for the EU’ ¹⁶ and in the ‘Simpler and Faster Europe: Communication on implementation and simplification’ ¹⁷ , the Commission emphasised the need to enhance competitiveness, foster innovation, and support growth across the Union, for which simplification and reducing administrative burden are critical enabling factors. It is therefore necessary to address costly regulatory burdens, complexities of the legislation and its implementation, including excessive reporting, while paying attention to the specific needs of small and medium entities.

(2) The Commission Communication ‘A Vision for Agriculture and Food’ ¹⁸ stresses that to drive innovation and sustainability in agricultural practices farmers should be entrepreneurs and providers not carrying unnecessary bureaucratic or regulatory burdens. This perspective and the sector’s diversity call for tailored approaches rather than ‘one-size-fit-all’ solutions, alongside reality-checks of the Union legislation, and simplifications, considering also the benefits brought by digital technologies, such as those enabling automated reporting. A better balance between requirements and incentives is needed for guiding the sustainability transition of farming and fostering innovation. The special needs of small farms, which underpin the vitality of rural communities, by protecting nature and livelihoods, call for more fitted and straightforward support under the Common Agricultural Policy (CAP), minimising administrative burden. Small farms and some other farms are often at a disadvantage in accessing and utilising funding, hindering their ability to invest, innovate and pursue development opportunities.

(3) Regulation (EU) 2021/2115 of the European Parliament and of the Council ¹⁹ establishes rules on support for strategic plans to be drawn up by Member States under the common agricultural policy (CAP Strategic Plans) and financed by the European Agricultural Guarantee Fund (EAGF) and by the European Agricultural Fund for Rural Development (EAFRD). Regulation (EU) 2021/2116 of the European Parliament and of the Council ²⁰ establishes rules on the financing, management and monitoring of the common agricultural policy. In 2024, Regulation (EU) 2024/1468 of the European Parliament and of the Council ²¹ was adopted with the aim to better adjust the Union CAP support framework to on-farm realities, improve administration of the CAP Strategic Plans by Member States and reduce the burden related to controls. Also, the Commission adopted Delegated Regulation (EU) 2024/1235 ²² amending Delegated Regulation (EU) 2022/126 ²³ , as regards rules on the ratio for the good agricultural and environmental condition (GAEC) standard 1, providing in particular for the possibility for Member States to adjust the reference ratio for GAEC standard 1 based on structural changes in farming systems and for derogations from the obligation to impose reconversion obligations on farmers and other beneficiaries.

(4) Feedback and experience from the two years of implementation of the CAP Strategic Plans under the current CAP Union legal framework indicate that further, limited adjustments of that legislation are needed in order to address the identified bottlenecks and complexities. These include the fact that specific circumstances, practices and needs of certain groups of farmers - such as organic, young, small-scale, and livestock farmers - are not yet sufficiently taken into account in the CAP Union legal framework, which does not permit Member States to adjust the various instruments to the specific circumstances, needs and practices of those farmers. Also, certain simplification opportunities within the CAP, such as the use of lump-sums or simplified cost options, are underutilised due to complexities in their implementation and management. This can lead to overlapping or ambiguous requirements for farmers, complicate farmers’ access to support, and hinder business development opportunities for farmers, such as for young and new farmers. There are also certain rigidities in the rules impacting how Member States manage and amend their CAP Strategic Plans and fulfil their reporting obligations. Finally, the burden of on-farm-visits and controls on both farmers and administrative bodies still needs to be alleviated, in particular by introducing more efficient methodologies for Integrated Administration and Control System (IACS) quality assessments and conditionality controls. Overcoming these bottlenecks and rigidities should help Member States use the CAP Strategic Plans to maximise opportunities for the benefit of farmers and other beneficiaries of the CAP, reduce administrative burden and complexity, and make better use of scarce resources.

(5) Article 4(3), point (c), of Regulation (EU) 2021/2115 establishes that, when an agricultural area is used as a grassland and has not been included in the crop rotation of the holding for five years or more, it is to be considered as permanent grassland. However, some farming systems entail crop rotation on arable land where the grasses or other herbaceous forage are not included in the crop rotation for periods longer than five years, but where  these areas are ploughed up to remain arable land. As a consequence, farmers in the Member States where such farming systems are applied, face difficulties in managing their agronomic rotations and in remaining viable while meeting the requirements for the implementation of GAEC Standard 1. In addition, the use of longer crop rotations with grasslands may bring significant benefits in terms of biodiversity and ecosystem services, while allowing farmers greater flexibility in their agronomic management. Therefore, in order to promote such flexible and sustainable agronomic practices for the management of grasslands, it should be possible for Member States to extend the period determining the classification of an area as permanent grassland from five years to seven years. Thus, Article 4(3), point (c), of Regulation (EU) 2021/2115 should be amended.

(6) In order to minimise the risk of negative impacts on the single market and international trade of the new crisis payments to farmers following natural disasters, adverse climatic events and catastrophic events in accordance with Articles 41a and 78a of Regulation (EU) 2021/2115, the interventions under which this Union support is to be granted should be designed by the Member States in such a way that they qualify under the criteria of Annex 2 to the WTO Agreement on Agriculture (‘Green Box’).

(7) Article 11 of Regulation (EU) 2021/2115 provides for a mechanism for implementation of the Memorandum of Understanding on oilseeds, including provisions on increases of planned outputs and reduction coefficients to avoid exceeding the maximum support area for the whole Union. This provision need to be adjusted to take into account amendments of Article 119 of that Regulation, introduced by this Regulation.

(8) In view of the exceptional nature of the payment the farmer would receive in an crisis situation, having suffered significant production losses as a result of natural disasters, adverse climatic events or other catastrophic events, and to ensure coherence with payments referred to in Article 78a of Regulation (EU) 2021/2115, the system of conditionality referred to in Article 12 of that Regulation should not apply to complementary payments to farmers following natural disasters, adverse climatic events or catastrophic events under direct payments, referred to in Article 41a of that Regulation.

(9) The system of conditionality comprising Statutory Management Requirements (SMR) and Good Agricultural and Environmental Condition (GAEC) Standards aims to contribute to the development of sustainable agriculture through an increased awareness on the part of beneficiaries of the need to comply with those basic standards and requirements. It also aims to increase the consistency of the CAP with the environment, public health, plant health and animal welfare objectives pursued by Union legislation. However, considering that the agricultural area managed by small farmers who benefit from payments under the interventions referred to in Article 28 of Regulation (EU) 2021/2115 is limited, applying the system of conditionality to such small farmers, who manage majority of farms in the Union, yields insufficient benefits compared to significant costs, and imposes an important administrative burden, on those farmers and national administrations. To reduce such costs and ease the related administrative burden, it is appropriate to exempt small farmers from the application of the system of conditionality.

(10) The GAEC standards referred to in Article 13 of Regulation (EU) 2021/2115 are part of the conditionality system referred to in Article 12 of that Regulation. They contribute to the mitigation and adaptation to climate change, protection of the environment, including water, soil and biodiversity of ecosystems. The general principles on which organic production pursuant to Article 5 of Regulation (EU) 2018/848 of the European Parliament and of the Council ²⁴ is based include the preservation of natural landscape elements, such as natural heritage sites and the responsible use of energy and natural resources, such as water, soil, organic matter and air.

(11) GAEC standard 1, listed in Annex III to Regulation (EU) 2021/2115 aims to maintain permanent grassland to preserve carbon stock. Points 1.7.3 and 1.9.1.1 of Annex II to Regulation (EU) 2018/848 emphasize the importance of maximizing the use of grazing and pasture, which prevents the conversion of permanent grassland into other land uses, and in line with the main objective of GAEC standard 1 preserves carbon stock in permanent grasslands. GAEC standards 3, 5 and 6, listed in Annex III to Regulation (EU) 2021/2115 aim to maintain soil organic matter, limit erosion, and protect soils during sensitive periods, respectively. These objectives are already achieved through the tillage and cultivation practices applied in organic plant production, in particular those referred to in point 1.9. of Annex II to Regulation (EU) 2018/848. GAEC standard 4, listed in Annex III to Regulation (EU) 2021/2115, aims to protect water against pollution. Similarly, points 1.5, 1.7, 1.9 and 1.10 of Annex II to Regulation (EU) 2018/848 aim to reduce the risk of water pollution by limiting the use of veterinary medicinal products, restricting the use of fertilizers and pesticides, and restricting stocking density. Experience has shown that organic farming has a positive impact as regards nutrient leaching and run-off, making it less likely that an organic farmer would compromise the quality of water, thereby achieving the main objective of GAEC standard 4. Therefore, given the principles and rules laid down in Regulation (EU) 2018/848 and existing practices under the organic farming systems, organic farmers whose entire holding is certified in accordance with Regulation (EU) 2018/848 should be deemed to comply with GAEC standards 1, 3, 4, 5 and 6, as is the case already in respect to GAEC standard 7.

(12) To improve consistency of requirements for farmers and simplify the setting of the GAEC standards by the Member States, Article 13(1) of Regulation (EU) 2021/2115 should be amended to clarify that Member States may set out the GAEC standards in their CAP Strategic Plans consistently with mandatory national requirements, provided that such national requirements comply with the GAEC standards listed in Annex III to that Regulation. It should in particular be clarified that GAEC standards set in the CAP Strategic Plans do not need to go beyond existing mandatory national requirements, provided that those national requirements comply with GAEC standards listed in Annex III to Regulation (EU) 2021/2115, in particular with the main objectives of those GAEC standards.

(13) In view of the exceptional nature of the payment the farmer may receive in a crisis situation, having suffered significant production losses as a result of natural disasters, adverse climatic events or other catastrophic events, and to ensure coherence with the payments referred to in Article 78a of Regulation (EU) 2021/2115, the system of conditionality referred to in Article 14 of that Regulation should not apply to complementary payments to farmers following natural disasters, adverse climatic events or catastrophic events under the direct payments referred to in Article 41a of that Regulation.

(14) Natural disasters, adverse climatic events and catastrophic events are increasing in their frequency, intensity and duration and are having significant impact on the agricultural sector in the Union. Regulation (EU) 2021/2115 already provides a set of tools for farmers to build up resilience and respond to crisis. The scale of events and their sudden and extraordinary nature call however for expanding instruments available for Member States. Hence, it is appropriate to provide for complementary crisis payments to farmers and to include them as a new type of intervention in the form of direct payments in Article 16 of that Regulation.

(15) Article 19 of Regulation (EU) 2021/2115 allows Member States to retain up to 3 % of the direct payments to be paid to a farmer to support the farmers’ contribution to a risk management tool. A Member State deciding to make use of this option, had to apply it to all beneficiaries of direct payments in a given year. Experience shows that only very few Member States make use of this option. Discussions with the Member States have shown that an obstacle to the implementation of this provision is the lack of risk management tools, either set up by Member States or available through private insurance, available for all farmers receiving direct payments. In order to increase the uptake and use of the possibility provided for in Article 19 of that Regulation, it is necessary to make its implementation more flexible and to adapt it to the existing management tools in Member States. As a result of this amendment, Member States should be able to retain up to 3% of direct payments to be paid to those farmers only for whom risk management schemes exist in a given year. Member States where risk management schemes would exist for all direct payments beneficiaries should be able to continue retaining up to 3% of the direct payments of all such beneficiaries.

(16) The simplified payment scheme designed by Member States for small farmers under Article 28 of Regulation (EU) 2021/2115 reduces the complexity of the application process for income support, both for small farmers and for administrations. In order to enhance its attractiveness and encourage a larger number of small farmers to benefit from that scheme, the maximum amount that can be received under that scheme should be increased. In order to foster the participation of small farmers who benefit from the payments referred to in Article 28 of Regulation (EU) 2021/2115 in the eco-schemes referred to in Article 31 of that Regulation, Member States should have the possibility to exclude payments received by those farmers under eco-schemes from the maximum amount of payment referred to in Article 28 of that Regulation.

(17) Where a Member State decides pursuant to Article 28, second subparagraph, of Regulation (EU) 2021/2115 that the payment to small farmers referred to in Article 28, first subparagraph of that Regulation, is not to replace support for eco-schemes established in accordance with Article 31 of that Regulation, the eco-schemes should continue to comply with all requirements laid down in Article 31(5) of that Regulation. This principle should also be respected as regards interventions under Article 70 of that Regulation in respect of farmers receiving payments referred to in Article 28 of that Regulation. In order to ensure compliance with the general principle that payments are only provided for commitments going beyond the conditionality requirements, and to safeguard the ambition of the interventions, which form part of the environmental and climate architecture of the CAP, farmers receiving payments referred to in Article 28 of Regulation (EU) 2021/2115 should only receive payments under eco-schemes referred to in Article 31 of that Regulation or payments under interventions referred to in Article 70 of that Regulation if they comply with the conditions laid down in Article 31(5), first subparagraph, point (a) of that Regulation or the conditions laid down in Article 70(3), first subparagraph, point (a) of that Regulation, respectively.

(18) To ensure that when Member States increase the delivery of environmental, climate, animal welfare and anti-microbial resistance objectives, by maintaining or adopting national legislation which goes beyond the corresponding minimum requirements laid down in Union law, the  impact of such requirements on the financial and economic situation of the farmers concerned may be kept limited, Article 31(5) of Regulation (EU) 2021/2115 needs to be amended to allow Member States to grant support for commitments contributing to compliance with mandatory requirements imposed by national law going beyond the minimum requirements laid down in Union law, irrespective whether they have been newly imposed or were existing already. Furthermore, lifting the limitation of the period during which support may be granted for commitments under eco-schemes should simplify the management of the eco-schemes for Member States, as it should reduce the need for modifications of eco-schemes in the CAP Strategic Plans during this programming period due to changes of such national legislation or due to the expiry of the 24 months period during which support may be granted for commitments contributing to compliance with such national legislation.

(19) GAEC standard 2, listed in Annex III to Regulation (EU) 2021/2115, aims to protect carbon-rich soils. Experience has shown that the requirements set out in the CAP Strategic Plans under the GAEC standard 2 have created challenges for farmers and Member States, particularly as regards the economic viability of the farmers concerned while guaranteeing the protection of carbon-rich soils. Compliance with certain requirements established under GAEC standard 2, such as those involving production limitation may be costly for farmers and significantly limit their capacity to change or adjust the use of their land. Besides, GAEC standard 2 impacts farmers in some Member States more than in others due to the varying proportions of wetlands and peatlands within their territories. While maintaining the existing requirements under GAEC standard 2, where appropriate, set out consistently with mandatory national requirements, as introduced by this Regulation, it should be possible to compensate farmers for the compliance with the obligations resulting from this standard. It should therefore be possible for Member States to exclude GAEC standard 2 from the requirement laid down in Article 31(5), point (a), of Regulation (EU) 2021/2115. This should enable Member States to provide in their CAP Strategic Plans support under the eco-schemes referred to in Article 31 of that Regulation in order for active farmers concerned by GAEC standard 2, to meet the requirements of that standard while maintaining a high level of protection of wetlands and peatlands, in particular the carbon sequestration potential of these areas.

(20) In order to enable support for organic farming methods for livestock as a part of the eco-schemes referred to in Article 31 of Regulation (EU) 2021/2115, it should be possible for Member States to decide that support granted to commitments related to the conversion or maintenance of organic farming practices and methods in accordance with Regulation (EU) 2018/848 may take the form of an annual payment for livestock units. It should also be clarified that support for commitments improving farming practices related to apiculture may be granted in the form of annual payment for beehives as this will simplify the calculation of payments for those commitments. To ensure coherence of the definitions used in the CAP Strategic Plans, the notion of beehive for the purposes of granting support under eco-schemes referred to in Article 31 of Regulation (EU) 2021/2115 should be the notion of beehive defined by the Commission on the basis of Article 56, point (b), of that Regulation.

(21) In the first years of implementation of the CAP Strategic Plans, natural disasters, adverse climatic events or other catastrophic events have impacted many farmers’ production around the Union. That trend is expected to continue in the future. It should therefore be possible for Member States to offer crisis payments in the form of increased direct income support to enable the most affected farmers to be compensated rapidly. To maintain the incentive for farmers to insure their production, Member States should set a higher rate of compensation for those farmers, who are covered by an insurance scheme or other risk management tool. To increase the funds to be mobilised in support of farmers, Member States should be allowed to co-finance those crisis payments with additional national financing of up to 200 %. However Member States should ensure that the total compensation received by the farmer accumulated with other forms of Union or nationally funded support (including additional national financing), private insurance or other risk management schemes does not lead to overcompensation or double-funding.

(22) Article 48 of Regulation (EU) 2021/2115 should be amended to delete the reference to annual performance clearance, in view of the removal of that procedure from Regulation (EU) 2021/2116 by this Regulation.

(23) Producer organisations and associations of producer organisations in the fruit and vegetables sector play an important role in reinforcing the position of farmers in the supply chain. Support from the CAP to those organisations is of critical importance to address specific issues and sectoral objectives or to reward beneficial practices. It is therefore appropriate to allow producer organisations and associations of producer organisations implementing in their operational programmes one or more sectoral interventions linked to any of the objectives referred to in Article 46, points (d), (e), (f), (h), (i) or (j), of Regulation (EU) 2021/2115 to benefit from the increased limit for Union financial assistance referred to in Article 52(2) of that Regulation, provided that the amount in excess of the limits laid down in Article 52(2), first subparagraph, of that Regulation is spent solely to finance these sectoral interventions.

(24) Article 69 of Regulation (EU) 2021/2115 should be amended to align the title of the type of intervention for rural development referred to in point (e) of that Article with the amendments of Article 75 of that Regulation and to include the title of the new type of intervention referred to in Article 78a of that Regulation.

(25) To ensure that when Member States increase the delivery of environmental, climate, animal welfare and anti-microbial resistance objectives, by maintaining or adopting national legislation which goes beyond the corresponding minimum requirements laid down in Union law, the impact of such requirements on the financial and economic situation of the farmers concerned may be kept limited, Article 70(3) of Regulation (EU) 2021/2115 needs to be amended to allow Member States to grant support for commitments contributing to compliance with mandatory requirements imposed by national law going beyond the minimum requirements laid down in Union law, irrespective whether they have been newly imposed or were existing already. Furthermore, lifting the limitation of the period during which support may be granted for agri-environment-climate commitments should simplify the management of those commitments for Member States, as it should reduce the need for modifications of those interventions in the CAP Strategic Plans during this programming period due to changes of such national legislation or due to the expiry of the 24 months period during which support may be granted for commitments contributing to compliance with such national legislation.

(26) Experience has shown that the requirements set out in the CAP Strategic Plans under the GAEC standard 2 have created significant challenges for farmers and Member States, particularly as regards the economic viability of the farmers concerned while guaranteeing the protection of carbon-rich soils. Compliance with certain requirements established under GAEC standard 2, such as those involving production limitation may be costly for farmers and significantly limit their capacity to change or adjust the use of their land. Besides, GAEC standard 2 impacts farmers in some Member States more that in others due to the varying proportions of wetlands and peatlands within their territories. While maintaining the existing requirements under GAEC standard 2, where appropriate, set out consistently with mandatory national requirements, as introduced by this Regulation, it should be possible to compensate farmers for the compliance with the obligations resulting from this standard. It should therefore be possible for Member States to exclude GAEC standard 2 from the requirement laid down in Article 70(3), point (a), of Regulation (EU) 2021/2115 for interventions based on Article 70 of that Regulation. This should enable Member States to provide in their CAP Strategic Plans support under interventions referred to in Article 70 of that Regulation, in order for farmers and other beneficiaries concerned by GAEC standard 2, to meet the requirements of the standard while maintaining a high level of protection of wetlands and peatlands, in particular the carbon sequestration potential of these areas.

(27) Pursuant to Article 70(8) of Regulation (EU) 2021/2115, Member States are to establish payments for agri-environment-climate commitments as well as commitments to convert to or maintain organic farming only as payments per hectare. In order to ensure consistency with support under the eco-schemes referred to in Article 31 of that Regulation, it should be possible for Member States, in duly justified cases, to grant support for such commitments in the form of a payment per livestock unit. In order to facilitate activities beneficial for the environment in the case of beekeeping, it should be possible to grant support for agri-environment-climate commitments or commitments to convert to or maintain organic farming in the form of a payment per beehive. To ensure coherence of the definitions used in the CAP Strategic Plans, the notion of beehive for the purposes of granting support for these commitments should be the notion of beehive defined by the Commission on the basis of Article 56, point (b), of Regulation (EU) 2021/2115.

(28) Article 72(5) of Regulation (EU) 2021/2115 lays down rules concerning the calculation of additional costs and income foregone to grant payments for area-specific disadvantages resulting from certain mandatory requirements that go beyond the relevant GAEC standards. It does not grant payments for area-specific disadvantages resulting from the relevant GAEC standards. However, compliance with certain requirements established under GAEC standard 2 may be costly for farmers as they involve production limitations due to significant land use restrictions. In order to integrate in the principles of calculation of payments for area-specific disadvantages resulting from certain mandatory requirements costs related to the respect of GAEC standard 2, it should be possible for Member States to include in that calculation disadvantages resulting from the requirements of GAEC standard 2.

(29) To ensure that farmers have more time and flexibility to adjust to new Union legislation in an increasingly challenging context of geopolitical tensions, structural challenges and economic difficulties related, among others, to high energy and input prices, Article 73(5) of Regulation (EU) 2021/2115 should be amended to extend the period during which support may be granted for investments contributing to compliance with new requirements imposed by Union law from 24 months to 36 months from the date on which these new requirements become mandatory for the holding.

(30) The Union's farming sector faces demographic difficulties, with an ageing workforce. While attracting young farmers is key to ensuring a sustainable future for agriculture, the creation and development of new economic activity in the agricultural sector by young farmers is financially challenging. In order to further facilitate their setting up for the first time, the period of eligibility for investments to comply with new Union standards should be extended for young farmers.

(31) To strengthen the competitiveness and sustainability of the Union food system, significant investments and development of businesses are needed. Especially, the development of small farms, which are facing particular challenges and are potentially economically viable, should be encouraged. At the same time, there is a need to simplify the implementation of support for small farms to minimise the administrative burden. To address these needs, it is appropriate to amend Article 75 of Regulation (EU) 2021/2115 to include the business development of small farms among the interventions that Member States may support and to provide for a lump sum support of EUR 50 000 for that intervention. For reasons of consistency, Member States should define small farms in the same way for the purposes of investments pursuant to Article 73(4), point (b) of that Regulation and for the purposes of business development pursuant to Article 75 of that Regulation.

(32) Risk management interventions are very useful in making farmers more resilient and hence should be encouraged. However, experience has shown that current rules are too rigid to use this type of intervention to its full potential. In particular, it appears that the current formula for the calculation of losses is not adapted to the specific situation of certain beneficiaries, such as young farmers, areas with permanent crops or other justified cases for which the calculation formula of losses is not appropriate. To increase the use and uptake of risk management tools under Article 76 of Regulation (EU) 2021/2115, Member States should have more flexibility for calculating the losses for such beneficiaries or crops, to take into account their specific situations.

(33) In order to efficiently support farmers whose production was damaged by natural disasters, adverse climatic events or other catastrophic events, Member States should be able to plan crisis payments not only through direct income support interventions, but also through rural development interventions. Such types of support should offer Member States sufficient flexibility in planning the interventions. However, Member States should ensure consistency between these interventions. Accordingly, provisions regarding the targeting of support and the incentive effect should be the same. In order to ensure sound financial management of the Union funds, Member States should ensure that the total compensation received by the farmer accumulated with other forms of Union or nationally funded support (including additional national financing), private insurance or other risk management schemes does not lead to overcompensation or double-funding.

(34) Article 79(1) of Regulation (EU) 2021/2115 lays down the rules concerning the setting out by managing authorities of selection criteria for interventions relating to certain types of intervention. The list of types of intervention for which Member States are to use selection criteria should be amended to take into account the amendments to the types of intervention referred to in Article 75 of that Regulation.

(35) Article 80 of Regulation (EU) 2021/2015 lays down the rules and principles for implementation of financial instruments in the CAP. Article 80(2) of that Regulation ensures consistency with the provisions of Regulation (EU) 2021/1060 of the European Parliament and of the Council ²⁵ concerning financial instruments. To further strengthen the synergy in the implementation and control between CAP financial instruments and the other financial instruments governed by Regulation (EU) 2021/1060, Article 80 of Regulation (EU) 2021/2115 should be amended to ensure that the requirements regarding the audit trail for financial instruments are the same in Regulation (EU) 2021/2115 and in Regulation (EU) 2021/1060.

(36) Article 80(3) of Regulation (EU) 2021/2115 sets out the maximum applicable gross grant equivalent ceiling when financial instruments support activities falling within the scope of Article 42 of the Treaty. To ensure alignment with the newly introduced changes in the general State aid regime under Article 3(2) of Commission Regulation (EU) 2023/2831 ²⁶ , the ceiling needs to be increased accordingly. Furthermore, the reference period should be changed from ’fiscal‘ years to ’years‘ to align with Article 3(2) of that Commission Regulation. As regards support for working capital for activities outside the scope of Article 42 TFEU, general state aid rules continue to apply.

(37) Article 80(5) of Regulation (EU) 2021/2115 defines the eligibility of expenditure when support is provided through financial instruments. To ensure clarity and equal treatment under all financial instruments governed by Regulation (EU) 2021/1060, Article 80(5) of Regulation (EU) 2021/2115 should be amended to set out the eligibility rules with regard to the value-added tax (‘VAT’).

(38) Article 81 of Regulation (EU) 2021/2015 lays down the rules and conditions for transfers by Member States of EAFRD allocations to InvestEU Programme established by Regulation (EU) 2021/523 of the European Parliament and of the Council ²⁷ . To ensure full uptake of newly introduced possibilities under Article 10a(4) of Regulation (EU) 2021/523, Article 81 of Regulation (EU) 2021/2115 should be amended..

(39) Article 83 of Regulation (EU) 2021/2115 lays down the rules for calculating and applying simplified cost options. To simplify and boost the implementation of investments and other rural development interventions and to increase the use of simplified cost options, it should be possible to use the calculation methods established under Regulation (EU) 2021/1060 without the need to provide further justification.

(40) Article 86(2) and (3) of Regulation (EU) 2021/2115 lays down rules on the eligibility of expenditure resulting from amendments of CAP Strategic Plans for contribution from the EAGF and the EAFRD, respectively. To simplify the rules on eligibility of expenditure, to improve synergies between the EAGF and the EAFRD and to increase the flexibility for the Member States to determine the dates of effect of the EAGF-related amendments of CAP Strategic Plans, it is appropriate to allow the eligibility of expenditure resulting from an approved strategic amendment of a CAP Strategic Plan for EAGF contribution from the date of effect of the amendment set by the Member State concerned in accordance with Article 119(8) of that Regulation, but not earlier than from the date of submission to the Commission of the request for amendment. For other amendments of CAP Strategic Plans related to the EAGF, the expenditure should be eligible for contribution from the EAGF from the date of notification of the amendment to the Commission, as laid down in Article 119(9) of Regulation (EU) 2021/2115, as amended by this Regulation. To ensure coherence between the rules concerning eligibility for contribution from the EAGF and EAFRD in cases of emergency measures due to natural disasters, catastrophic events or adverse climatic events, it should be possible to establish in CAP Strategic Plans that the eligibility of EAGF-financed expenditure relating to amendments to CAP Strategic Plans related to complementary crisis payments to farmers under direct payments referred to in Article 41a of that Regulation, may start from the date on which the event occurred.

(41) For the purpose of ensuring adequate financing for the new types of intervention for crisis payments to farmers following natural disasters, adverse climatic events or catastrophic events referred to in Articles 41a and 78a of Regulation (EU) 2021/2115, Member States should be able to reserve a certain share of both direct payments and EAFRD funding for these types of intervention. However, with a view of ensuring that sufficient financing remains available to deliver on the other CAP priorities, this share should be limited to a maximum annual amount available per Member State corresponding to 3 % of the total of direct payments and EAFRD funding per year. In order to incite Member States to privilege the use of the instrument set out in Article 41a of that Regulation and financed with direct payments funding, the maximum annual amount that can be reserved by a Member State for this type of intervention should correspond to 4 % of the total of direct payments and EAFRD funding per year, if the Member State decides not to provide support for crisis payments under Article 78a of that Regulation.

(42) Due to their special nature, the new types of intervention for crisis payments to farmers under direct payments referred to in Article 41a of Regulation (EU) 2021/2115 and under rural development referred to in Article 78a of that Regulation should be exempt from the obligation to contribute to the result indicators listed in Annex I to that Regulation.

(43) Additional national financing for complementary crisis payments to farmers provided in accordance with Article 41a of Regulation (EU) 2021/2115 should be included in Annex V to the CAP Strategic Plan of the Member State.

(44) Article 119(4) of Regulation (EU) 2021/2115 provides for the approval by the Commission of requests for amendments of CAP Strategic Plans submitted by Member States. Article 119(9) of that Regulation enables Member States to make and apply modifications of CAP Strategic plans related to the interventions referred to in Title III, Chapter IV, of that Regulation, which are approved by the Commission together with the next request for amendment. Experience has shown that the amendments of CAP Strategic Plans often contain numerous technical elements that render them complex, onerous for Member States, and result in delays in the approval procedures although the strategic orientation of the Plans remain unchanged. This interferes with timely and effective adaptation of CAP Strategic Plans to changing economic reality and needs of farmers and other beneficiaries in Member States and negatively impacts the implementation of those Plans. To simplify and improve the efficiency of amendment procedures, in particular regarding elements of the CAP Strategic Plans that are not of strategic nature, approval by the Commission should be required only for strategic amendments of CAP Strategic Plans. For this purpose, strategic amendments should be defined in Regulation (EU) 2021/2115 as amendments of important elements of the CAP Strategic Plans that significantly impact the strategy and intervention logic of those plans, including transfers of financial allocations between the EAFRD and the EAGF, maximum and minimum financial allocations, and changes to target and financial plans. Member States should be able to make and apply all other amendments to their CAP Strategic Plans upon notifying them to the Commission, and these other amendments should not be subject to Commission approval.

(45) To ensure compatibility of the CAP Strategic Plans with the Union CAP legal framework, the Commission should have the power to object to notified amendments where it considers that those amendments are not compatible with Regulation (EU) 2021/2115, Regulation (EU) 2021/2116 or the delegated and implementing acts adopted pursuant to them. To ensure legal certainty for farmers and other beneficiaries, the Member States should upon receipt of an objection to a notified amendment not apply that amendment and remove such amendment from the amended CAP Strategic Plan submitted to the Commission. Expenditure related to such amendments should also not be eligible for a contribution from the EAFG or the EAFRD, respectively. The experience shows that Member States may notify complex and numerous amendments to their CAP Strategic Plans. The Commission should therefore have a reasonable period of time to assess the notified amendments and to make objections to the Member States, where necessary. Member States should have the possibility to submit amendments to which Commission made objections for approval as a part of a request for strategic amendment referred to in Article 119(2) of Regulation (EU) 2021/2115, as amended by this Regulation, to ensure that those amendments only take legal effect if they comply with Regulation (EU) 2021/2115 and Regulation (EU) 2021/2116, as well as delegated and implementing acts based on them.

(46) Article 119(8), third subparagraph, of Regulation (EU) 2021/2115 provides that Member States are to determine a date of effect for amendments of CAP Strategic Plans related to the EAGF for a date that is later than the date of approval of the request for amendment by the Commission. To increase the flexibility for the Member States in setting the dates of effect for EAGF-related strategic amendments of CAP Strategic Plans and to increase synergies between the rules applicable to EAGF-related strategic amendments of CAP Strategic Plans and EAFRD-related amendments of CAP Strategic Plans, it should be possible for Member States to set the date of effect of strategic amendments of CAP Strategic Plans between the date of the submission to the Commission of the request for approval of strategic amendment referred to in Article 119(2) of Regulation (EU) 2021/2115, as amended by this Regulation, and the date of approval of the request for amendment by the Commission.

(47) Article 120 of Regulation (EU) 2021/2115 ensures that the CAP Strategic Plans are updated to reflect amendments made to the legislative acts listed in Annex XIII to that Regulation concerning the environment and climate to which the CAP Strategic Plans should contribute to and be consistent with. For that purpose, Member States are to assess whether their CAP Strategic Plans should be amended, and where necessary are to submit a request for amendment, where any of the legislative acts is modified. In order to avoid unnecessary administrative processes in the late phase of implementation of CAP Strategic Plans Article 120 of Regulation (EU) 2021/2115 should be deleted.

(48) Article 122 of Regulation (EU) 2021/2115 should be adjusted to reflect the amendments of Article 119 of that Regulation, introduced by this Regulation.

(49) Article 124(4) of Regulation (EU) 2021/2115 should be amended to enable the Monitoring Committee to give its opinion on the date of effect of all EAGF-related amendments to ensure that farmers and beneficiaries have sufficient time to take the proposed amendments into account.

(50) Article 134 of Regulation (EU) 2021/2115 sets out requirements on the content and procedure for annual performance reports, which are a basis for annual performance clearance referred to in Article 54 of Regulation (EU) 2021/2116. In view of the removal of the annual performance clearance procedure by this Regulation, these requirements should be modified to delete information required solely for the purposes of that procedure, such as information on realised unit amounts and justifications to be provided by Member States where the realised unit amounts exceed the corresponding planned unit amounts set out in the CAP Strategic Plans.

(51) Article 134(7) of Regulation (EU) 2021/2115 needs to be clarified to strengthen the link between the annual performance report and the biennial performance review referred to in Article 135 of that Regulation, as regards the inclusion in the annual performance report of justifications for shortfalls from milestones for the purposes of biennial performance review.

(52) Pursuant to Article 134(13) of Regulation (EU) 2021/2115, the Commission may make observations on an admissible annual performance report within one month from its submission. Experience has shown that the assessment of admissibility of the annual performance report pursuant to Article 134(3) of that Regulation and a comprehensive assessment of the submitted annual performance report cannot be carried out in parallel with one another. It is therefore necessary to modify the date from which the time limit for sending observations, referred to in Article 134(13) of that Regulation, is calculated, to the date on which the annual performance report becomes admissible, in accordance with Article 134(3) of that Regulation.

(53) Additional national financing for complementary crisis payments to farmers provided in accordance with Article 41a of Regulation (EU) 2021/2115 should be subject to the same rules as additional national financing under rural development.

(54) Pursuant to Article 159 of Regulation (EU) 2021/2115 the Commission is to review the list of legislative acts in Annex XIII to that Regulation and make legislative proposals to add additional legislative acts to that Annex. In view of the deletion of Article 120 of that Regulation, Article 159 of that Regulation should be deleted to ensure coherence, stability and to avoid disrupting the implementation of CAP Strategic Plans by national authorities, farmers and other beneficiaries.

(55) Annex I to Regulation (EU) 2021/2115 sets out impact, result and output indicators pursuant to Article 7 of that Regulation. The table ‘Annual performance clearance – OUTPUT’ in Annex I to that Regulation should be replaced to introduce output indicators linked with the newly introduced types of intervention and the amended types of intervention and to take into account the deletion by this Regulation of the annual performance clearance provided for in Article 54 of Regulation (EU) 2021/2116.

(56) Annex II to Regulation (EU) 2021/2115 lists the relevant paragraphs of Annex 2 to the WTO Agreement on Agriculture (‘Green Box’) for each type of intervention of that Regulation. The newly introduced types of intervention for crisis payments to farmers under direct payments referred to in Article 41a of Regulation (EU) 2021/2115 and for rural development referred to in Article 78a of that Regulation should therefore be included in that Annex.

(57) GAEC standard 1, listed in Annex III to Regulation (EU) 2021/2115, aims to maintain permanent grasslands to preserve carbon stock based on a ratio of permanent grassland in relation to agricultural area at national, regional, subregional, group-of-holdings or holding level in comparison to the reference year 2018, with a maximum decrease of 5 % compared to the reference year. Structural changes to farms that may occur during the programming period 2023-2027, in particular in the livestock sector. These changes may be accompanied by rapid changes in land use at the farm level, in particular to mitigate the impacts of climate change on feed and fodder availability, which may however only show in the available data with a delay. Such evolution of structural changes to farms may lead to variations in the annual ratio of permanent grasslands compared to the reference year 2018. In view of these variations and with a view to facilitating the implementation of GAEC standard 1, the maximum percentage of the decrease of the ratio of permanent grassland compared to the reference year 2018 should be increased to 10 %, to enable the Member States to take into account the developments during the programming period 2023-2027 and needs of farms, in particular in the livestock sector.

(58) GAEC standard 4, listed in Annex III to Regulation (EU) 2021/2115, aims to protect river courses against pollution and run-off by the establishment of buffer strips along water courses. Experience has shown that Member States should have the possibility to align the definition of 'water course' for the purposes of this GAEC standard with the definition of water course established by Member States in national legislation, including national legislation implementing the Union legislation, which is part of SMR listed in Annex III to that Regulation. The definition of water course used by the Member States for the purposes of GAEC standard 4 should however be in line with the main objective of that GAEC standard, in particular to reduce the risk of excluding smaller water courses, that could carry pollution downstream, from the scope of that GAEC standard.

(59) Enhancing interoperability, including seamless exchange of data, between public agricultural information systems offers a range of operational, statistical, and policy-related benefits, such as reduced data collection burden and improved efficiency, automated data integration and validation, improved data accuracy and reliability, enhanced policy monitoring and more effective collaboration within Member States. However, the absence of a coordinated structure at Member State level, as well as the differences observed in the progress of digital transition among Member States inhibit the effective implementation of interoperability and its benefits. In line with the Commission Communication ‘A Vision for Agriculture and Food’, which underlines the ‘collect once, use multiple times’ principle, Member States should ensure that data is collected only once by the authorities responsible for the implementation, monitoring and evaluation of the CAP and re-used, without asking the farmers several times to provide the same data.

(60) To achieve and maintain interoperability between information systems used for the implementation, monitoring and evaluation of the CAP, and seamless exchange of data between those information systems for the benefit of farmers and other CAP beneficiaries and the administration, and potentially the wider economy, and in consideration of the European Strategy of Data ²⁸ and other relevant EU and national initiatives, such as the Common European Agricultural Data Space and the Interoperable Europe Act ²⁹ , each Member State should designate one authority responsible for drawing up and implementing a roadmap containing measures and actions. For that purpose, the designated authority should, where relevant, collaborate with other national authorities and Union institutions and bodies. To ensure a timely and appropriate follow-up by the Commission, the Member States should submit to the Commission their Roadmaps. The Commission should have the possibility to make observations on the Roadmaps submitted by Member States with the view to ensuring coherence and enhancement of interoperability between public agricultural information systems. A non-harmonized approach on digital identifiers or data sharing mechanisms hampers progress on interoperability. For that purpose, Member States should consider the establishment of a single digital identity framework and alignment with Regulation (EU) No 910/2014 of the European Parliament and of the Council ³⁰ , including as regards the European Digital Identity Wallet for natural and legal persons. The Member States should establish and implement the Roadmap based on their specific situation and needs and should ensure that it contains the measures needed to achieve and maintain interoperability between public agricultural information systems as well as timeline within which these measures would be implemented. The designation of the Authority as well as the drawing-up and implementation of the Roadmap should not be considered as basic Union requirements, referred to in Article 2, point (c), of Regulation (EU) 2021/2116.

(61) Experience with the implementation of the agricultural reserve has shown that it is valuable in case of crisis in order to offer support to farmers affected and to contribute to the return of markets to a better balance. However, in the past years it was increasingly used for alleviating the situation of the farmers suffering direct losses due to natural disasters, adverse climatic events or catastrophic events although its intended original purpose as financing market instrument was to focus on compensating and mitigating the impacts of market disturbances. In view of the mounting challenges faced by the Union agricultural sector, including trade tensions, geopolitical uncertainty and increased indirect impact of animal health issues on market balance, it appears justified to refocus the reserve on its original purpose. Compensations to farmers for direct effects of natural disasters, adverse climate events or catastrophic events, such as those resulting in physical losses of plants, animals and products thereof should be addressed by Member States who are in charge of developing robust risk and crisis management strategies with the financial support of their CAP Strategic Plans including the new instruments established by this Regulation. Measures to balance the negative impact on farmers generated by market disturbance such as those affecting prices, costs or sales, also when they are generated as indirect effects of natural disasters, adverse climate events or catastrophic events, should continue to be financed by the agricultural reserve.

(62) Article 21(1) and Article 32(8) of Regulation (EU) 2021/2116 setting out rules on monthly and interim payments, respectively, should be amended to take into account the deletion by this Regulation of the annual performance clearance provided for in Article 54 of that Regulation. Moreover, Article 21(2) of Regulation (EU) 2021/2116 should be also amended in order to ensure that, following the amendments introduced by this Regulation in Article 86(2) and Article 119(8) of Regulation (EU) 2021/2115, expenditure that becomes eligible for EAGF contribution from a date of effect, which precedes the approval of the amendment by the Commission but follows the date of submission to the Commission of the request for amendment, is declared to the Commission only after the approval of the amendment by the Commission in accordance with Article 119(10) of Regulation (EU) 2021/2115. To this end, it should be possible to declare expenditure, which cannot be declared in the month concerned due to a pending approval of an amendment, in the subsequent months of the same financial year or, at the latest, in the annual accounts of that financial year to be sent to the Commission by 15 February of the year following that financial year. When determining the date of effect of an amendment and in order to ensure that any expenditure resulting from the amendment already paid to beneficiaries can be still declared within the respective financial year, Member States should take into account the time limits for the approval procedure laid down in Article 119 of Regulation (EU) 2021/2115.

(63) Article 40 of Regulation (EU) 2021/2116 on suspension of payments in relation to the annual performance clearance needs to be amended to take into account the deletion by this Regulation of the annual performance clearance provided for in Article 54 of that Regulation.

(64) Article 53 of Regulation (EU) 2021/2116 provides that based on the information referred to in Article 9(3), first subparagraph, points (a) and (d), of that Regulation, the Commission is to adopt implementing acts containing its decision on the clearance of the accounts of the accredited paying agencies for the expenditure referred to in Article 5(2) and Article 6 of that Regulation. Article 53 of Regulation (EU) 2021/2116 should be amended to take into account the deletion by this Regulation of the annual performance clearance provided for in Article 54 of that Regulation.

(65) Article 54 of Regulation (EU) 2021/2116 provides that where the expenditure referred to in Article 5(2) and Article 6 of that Regulation and corresponding to the interventions referred to in Title III of Regulation (EU) 2021/2115 does not have a corresponding output as reported in the annual performance report referred to in Article 9(3) and Article 10 of Regulation (EU) 2021/2116 and in Article 134 of Regulation (EU) 2021/2115, the Commission is to adopt implementing acts prior to 15 October of the year following the relevant budgetary year determining the amounts to be reduced from Union financing (‘annual performance clearance’). The experience gained from the first year of implementation of the annual performance clearance exercise, and from the preparation of the second-year exercise, shows that Member States bear a disproportionate administrative burden in the preparation and provision of the necessary information for the annual performance report as well as during the annual performance clearance. To alleviate the administrative burden on Member States, the annual performance clearance provided for in Article 54 of Regulation (EU) 2021/2116, should be abolished. The requirement that expenditure effected by paying agencies is to be matched by a corresponding output, laid down in Article 37(1), point (b)(i), of that Regulation, is covered by the conformity procedure referred to in Article 55 of that Regulation.

(66) The requirement that expenditure is to be effected in accordance with the applicable governance systems, laid down in Article 37(1), point (b)(ii), of Regulation (EU) 2021/2116 is controlled by the paying agencies, and afterwards verified by certification bodies on an annual basis, and by the Commission in the form of reviews of the Certification Body’s opinions and reports and as a part of follows up on the findings, as well as during conformity procedures referred to in Article 55 of that Regulation. These procedures provide the necessary assurance that realised outputs are achieved in compliance with Union legislation. Together with the biennial performance review referred to in Article 135 of Regulation (EU) 2021/2115, these procedures also ensure that Member States achieve the milestones and targets referred to in Article 109(1), point (a), of that Regulation, set by them as a part of their performance systems in the CAP Strategic Plans. Article 54 of Regulation (EU) 2021/2116 should therefore be deleted.

(67) Further alignment on financial instruments between the CAP and the other policies under shared management needs to be achieved in the context of irregularities and financial corrections, when bodies implementing financial instruments demonstrate the fulfilment of a cumulative set of actions. Therefore, Article 57 of Regulation (EU) 2021/2116 needs to be amended to ensure consistency with Article 103(6) of Regulation (EU) 2021/1060.

(68) Farmers have repeatedly reported the pressure of undergoing multiple controls throughout the year. Member States have already the possibility to group several controls in a single visit. In order to reduce the number of field visits per farm and thereby alleviating the administrative burden on beneficiaries, where possible, Member States should not select a beneficiary that has already been selected for an on-the-spot check for that year, except when the circumstances require a second control to ensure the protection of the financial interests of the Union. In addition, this reduction should not reduce the level of checks. For this purpose, Article 60(1) of Regulation (EU) 2021/2116 should be amended accordingly.

(69) Article 67(1) of Regulation (EU) 2021/2116 should be amended to remove the reference to annual performance clearance referred to in Article 54 of that Regulation.

(70) Based on the first years of implementation, it appears redundant to carry out on-the-spot checks on interventions that are monitored by Copernicus Sentinels satellite data or other data with at least equivalent value, entailing an unjustified burden for the Member States and farmers. Therefore, for those eligibility conditions , Member States should not be obliged to carry out on-the-spot checks, including those executed remotely with the use of technology. For this purpose, Article 72 of Regulation (EU) 2021/2116 should be amended accordingly.

(71) The experience gained shows that the quality assessments of, respectively, the Identification System for agricultural parcels (LPIS), the Geo-Spatial Application (GSA) and the Area Monitoring System (AMS) should be merged. Since the systems are intrinsically linked, assessing the quality of one system without considering the impact on the others is challenging. Moreover, by merging these quality assessments, Member States administrations would benefit from a reduced workload related to the inspection procedures and the reporting obligations. Additionally, when needed, Member States would have the advantage of proposing a single remedial action encompassing all three systems (LPIS, GSA and AMS), rather than implementing separate actions, increasing their efficiency. For this purpose, a new Article should be introduced in Regulation (EU) 2021/2116 and the relevant references should be amended accordingly.

(72) Experience gained in the application of the conditionality control system, including through conformity procedures, has shown that certain conditions are unnecessarily rigid and place an undue burden on Member States, without necessarily enhancing the protection of Union funds. To streamline the control system and reduce administrative burden while maintaining its effectiveness in verifying compliance with conditionality requirements, Member States should be granted greater flexibility in designing their control systems. To this end, the requirement for a yearly review of the control system should be removed and the factors to be considered in the risk analysis should be left to the discretion of Member States.

(73) Regulation (EU) 2024/1468 of the European Parliament and of the Council ³¹ amended Articles 83 and 84 of Regulation (EU) 2021/2216 to lessen the burden on small farmers and national administrations related to conditionality controls and penalties. Specifically, it exempts farmers with a maximum size of holding not exceeding 10 hectares of agricultural area declared in accordance with Article 69(1) of Regulation (EU) 2021/2116 from conditionality controls and from the application of administrative penalties for non-compliance with conditionality requirements. However, the geo-spatial application referred to in Article 69(1) of Regulation (EU) 2021/2116 includes areas other than agricultural area and there are technical constraints to calculate the agricultural areas, given that some of the elements and landscape features may not be measured and may vary in size over time. Therefore, the exemptions should be based on the area eligible for the payments and the support relevant for conditionality.

(74) Furthermore, small beneficiaries other than farmers, such as land managers, may not benefit from the exemptions from conditionality controls and penalties. However, the administrative burden linked to the controls and the application of penalties for those conditionality requirements provided for in Regulation (EU) 2021/2116 can also be disproportionately high for those beneficiaries. Likewise, since the area managed by those beneficiaries is limited and penalties are in general low for small beneficiaries, the application of penalties could also lead to disproportionate burden for Member States’ administrations. Therefore, small beneficiaries other than farmers should also be exempted from conditionality controls and from the application of administrative penalties for conditionality requirements. Nevertheless, it is important for the CAP to continue to contribute to the environmental objectives set out in Article 6(1), points (d), (e) and (f), of Regulation (EU) 2021/2115 through conditionality requirements and to ensure the stability of those requirements as the common baseline for Member States and beneficiaries. Therefore, the conditionality requirements should continue to apply to all beneficiaries listed in Article 83(1) of Regulation (EU) 2021/2116.

(75) Articles 102 and 103 of Regulation (EU) 2021/2116 laying down rules concerning exercise of delegation of power to adopt delegated acts and the committee procedure should be amended to take account of amendments of other provisions of Regulation (EU) 2021/2116 introduced by this Regulation, in particular the deletion of Article 54 of that Regulation.

(76) To ensure coherence among the various provisions of Regulation (EU) 2021/2116, that Regulation should be amended to remove references to annual performance clearance procedure, in particular to Article 54 and Article 40(1) of that Regulation.

(77) Regulations (EU) 2021/2115 and (EU) 2021/2116 should therefore be amended accordingly.

(78) Transitional provisions should be laid down in connection with amendments to Article 119 of Regulation (EU) 2021/2115, introduced by this Regulation, to ensure that requests for amendment and notifications of modifications of CAP Strategic Plans submitted by Member States to the Commission before the entry into force of this Regulation are approved using the procedures applicable at the time of submission of those requests for amendment or notifications.

(79) In order to ensure a smooth implementation of the measures introduced by this Regulation and as a matter of urgency in order to reduce the administrative burden for Member States authorities involved in the preparation of the annual performance report for financial year 2025, this Regulation should enter into force on the day following that of its publication in the Official Journal of the European Union.

(80) Given that funds have already been allocated from the 2025 agricultural reserve for sectors affected by adverse climatic events and natural disasters as provided for in Commission Implementing Regulation (EU) 2025/441 ³² , Article 2, point (5) of this Regulation should apply from the agricultural financial year 2026, i.e. from 16 October 2025 only.

(81) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation (EU) 2018/1725 ³³ of the European Parliament and the Council and delivered an opinion on [...]