On 9 January, the European Court of Auditors (ECA) issued its opinion on the Commission’s proposals for the next Common Agricultural Policy (CAP), for the period 2028-2034. The auditors commented on the design of the future CAP, with the purpose of ensuring sound financial management, accountability, and EU added value. They highlighted several risks arising from uncertainty and a lack of clarity, emphasising that EU funds must remain traceable and the CAP a common policy. 

In 2025, the Commission proposed a total budget of €2 trillion for the EU for the period 2028–2034 (next Multiannual Financial Framework – MFF). With a budget of around €865 billion, the NRP Fund would account for the largest share of the next MFF. The Common Agricultural Policy (CAP), currently the EU’s largest agricultural spending programme, would be funded by the new single fund based on national plans. This represents a significant structural shift, as it eliminates the CAP’s traditional two-pillar support system, whereby one pillar supports farmers and the agri-food sector and the other supports rural development.

National flexibility versus common objectives

According to the auditors, the scale of the proposed changes and the flexibility granted to EU countries when preparing their national plans make it difficult to produce realistic estimates of how the Commission’s proposals might affect national spending allocations. They warn that increased flexibility must not undermine the CAP’s shared objectives, including fair income for farmers, environmental protection, climate action, and food security, which, EVU would argue, encompasses protein diversification. Without a clear common framework and active steering from the Commission, there is a significant risk of an uneven playing field for farmers and market distortions. 

Budgetary uncertainty

From a financial planning perspective, ECA points to potential uncertainty because the overall level of CAP funding will only be determined after national plans under the new single fund have been approved. This situation may make it difficult for recipients to anticipate the level of support available at the planning stage, and it complicates comparisons between CAP spending under the current MFF and potential allocations under the next framework. From a diversification perspective, it makes it difficult to make long-term transition and investment plans at farm-level.

Legal and structural complexity of the CAP framework

ECA also underlines structural issues related to the new CAP framework itself. They consider that complex planning and implementation arrangements, combined with an increasingly intricate legal architecture, risk generating uncertainty, reducing predictability for beneficiaries, and delaying the disbursement of funds. EVU had come to the same conclusion in its own analysis of the CAP-relevant proposals.

Support for (protein) diversification
While the auditors remain relatively cautious formulating an opinion on broader social and  environmental aspects of the CAP proposals, the report does show openness on protein and the need to diversify EU agricultural production. ECA notably explicitly welcomes the proposed creation of a protein sector under the CMO regulation as a “positive development” that could “contribute to reducing the EU’s dependency on imported protein crops for animal feed”.

On the new diversification scheme under Article 4 agri-environmental and climate actions, under which Member States would have to support on-farm diversification in nitrate-surplus affected areas, the report wisely recommends specifying “the basis for calculating the nitrate surplus” in the CAP proposal. This would be a good first step to ensure uniform application and equal access to the scheme for farmers across the EU. However, EVU advocates for a removal of the established nitrate-surplus limitation of the scheme or a very low common threshold, to allow for preventive schemes as well.

Interested in the bigger policy picture? Read our CAP analysis, which explores the opportunities presented by the new CAP proposals for agricultural diversification and strengthening the production of plant and protein crops.