In relation to the provision of funding for groups classified under the specific disadvantage category, my Department has been in consultation with the European Commission.
The National Reserve must allocate funds initially to the priority categories of young farmer and new entrant. The European Commission advised that it is possible to provide funds for a specific disadvantage grouping from the national reserve. Each of the specific disadvantage groups must receive approval by the Commission.
My Department also queried with the Commission if a linear cut to the value of all payments made under the Basic Payment Scheme could be used to fund the National Reserve to an extent needed for the forgotten farmers. The Commission confirmed that my Department could not do this and could only use the funding available from natural replenishment, once the priority categories were fully funded. Funds are naturally replenished from unused payment entitlements and claw-back on trading entitlements without land.
In 2018, the Omnibus regulation made a provision for the allocation of funds for specific disadvantage groups from a linear cut to all payments made under the Basic Payment Scheme, provided that a linear cut was required to fund payments made to the priority categories under the National Reserve. However, a linear cut was not required to fund the National Reserve in 2018 or 2019.
Furthermore, Article 14 of EU Regulation 1307/2013 sets out the circumstances surrounding the flexibility between pillars. Ireland opted not to avail of the flexibility between pillars which under the regulation had to be notified to the Commission before 31 December 2013.