The EU’s Common Agricultural Policy Q&A: is its governance robust enough to deliver the EU’s nature and climate goals?

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The document argues that the CAP's governance structure is too weak to guarantee the achievement of the European Green Deal (EGD) targets. It highlights that the European Commission lacks the legal power to reject national Strategic Plans (SPs) based on non-binding EGD strategies, cannot force modifications to plans even when they conflict with EU environmental legislation, and possesses monitoring tools—such as interim evaluations—that lack binding legal consequences for Member States.

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  • The European Commission is unlikely to reject national CAP Strategic Plans (SPs) because the legal grounds for denial are limited to severe breaches of EU law or CAP Regulations, and the wording allowing for the approval of incomplete plans is vague.
  • The European Commission cannot legally reject a CAP Strategic Plan solely for failing to implement the European Green Deal, the Farm to Fork Strategy, or the Biodiversity Strategy, as these are non-legally binding 'soft-law' communications.
  • Annex XI, which lists key EU environmental regulations and directives, is insufficient to ensure alignment between the CAP and environmental law because correct implementation of these laws is not a prerequisite for receiving CAP funds, and there are no specific legal consequences if Member States fail to consider them when drafting SPs.
  • The European Commission lacks the authority to mandate modifications to CAP Strategic Plans even if they become inconsistent with EU environmental legislation; instead, Member States are responsible for deciding if modifications are necessary.
  • Monitoring mechanisms, such as the Commission's power to issue recommendations to facilitate EGD objectives or the interim evaluation of CAP funds by 2026, do not trigger legal obligations for Member States to change their plans.
  • The timing of the CAP performance reports, scheduled for 2027 and 2031, is criticized as problematic because the information will not be available in time to inform the drafting of the next CAP reform proposal.

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APA
Fornabaio, L., & Martin, S. (2020). The EU’s Common Agricultural Policy Q&A: is its governance robust enough to deliver the EU’s nature and climate goals? ClientEarth. https://www.clientearth.org/media/2hthmypj/the-eu-s-common-agricultural-policy-q-a-clientearth.pdf
Chicago
Fornabaio, Lara, and Sarah Martin. The EU’s Common Agricultural Policy Q&A: is its governance robust enough to deliver the EU’s nature and climate goals? ClientEarth, 2020. https://www.clientearth.org/media/2hthmypj/the-eu-s-common-agricultural-policy-q-a-clientearth.pdf.
Wikipedia
{{cite report |last1=Fornabaio |first1=Lara |last2=Martin |first2=Sarah |title=The EU’s Common Agricultural Policy Q&A: is its governance robust enough to deliver the EU’s nature and climate goals? |publisher=ClientEarth |date=September 2020 |url=https://www.clientearth.org/media/2hthmypj/the-eu-s-common-agricultural-policy-q-a-clientearth.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{fornabaio2020eus, author = {Fornabaio, Lara and Martin, Sarah}, title = {{The EU’s Common Agricultural Policy Q\&A: is its governance robust enough to deliver the EU’s nature and climate goals?}}, institution = {ClientEarth}, year = {2020}, month = sep, url = {https://www.clientearth.org/media/2hthmypj/the-eu-s-common-agricultural-policy-q-a-clientearth.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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