Ireland was one of a large number of Member States to sign up in 2011 to six key principles for simplification of the CAP, in the context of the CAP reform process. These principles are that:
- The CAP 2014-2020 must overall be simpler and cheaper for national authorities to administer, and have reduced administrative costs for recipients. Any increased cost or complexity to specific measures can only be justified where the benefits outweigh the costs,
- A risk-based approach should be applied to all controls on both administrations and recipients. This means that controls are reduced where the administration has demonstrated that they have a robust system of controls in place, or the recipient has a good track record. Equally, controls should - as is already the case - be increased where systemic problems have occurred,
- Member States should be given the discretion and flexibility in programming and to define the detailed control, monitoring and evaluation of schemes in a manner appropriate to their particular circumstances, providing they can demonstrate that the policy measures taken are effective,
- Greater proportionality should be applied to controls and penalties,
- Full transparency and clarity of all roles and responsibilities should be provided, and mechanisms put in place for providing the necessary clarity if there is any uncertainty about the interpretation of EU requirements,
- The use of technology should be maximise and incentivised.
Last year, we submitted a detailed paper to the Commission containing our proposals for simplification. The paper divided our concerns between policy and technical dimensions. The technical dimensions related to detailed article-by-article provisions of the draft CAP reform regulations. On policy, we stated our view that the formulation of policy in an overall sense should be informed by the need to keep things as simple as possible, and we highlighted some key concerns in this regard, namely:
- on direct payments, the fact that the proposals for a new payment model, the definition of ‘active farmer’ and a separate scheme for the ‘greening’ of direct payments would all add considerably to the administrative burden for Member States,
- on rural development, the fact that a complex framework to ensure coherence between spending from all EU funds, new ex-ante and macroeconomic conditionalities, and a new performance reserve would, similarly, add to Member States’ administrative burden,
- on financing and monitoring of the CAP, that there should be greater simplification of cross-compliance measures, the accreditation of payment agencies and the requirements for certifying bodies,
- that the general simplification of the regulatory framework, which is best exemplified in the single CMO proposals, should also result in practical benefits at farmer and administrative levels across all elements of the reform.
Many of our concerns have been taken on board in the subsequent negotiations, which, of course, are still ongoing.
