Talamh Beo | Political Briefing | October 23rd 2026
Response to Council document ST-14484-2026-INIT_en, concerning the Common Agricultural Policy 2028–2034
Talamh Beo is deeply concerned by amendments proposed in the Council Presidency’s partial general approach to the post-2027 Common Agricultural Policy (CAP).
Talamh Beo calls on the Minister for Agriculture Martin Heydon to state clearly if he supports the changes proposed by the Council.
If he does support these changes, as revealed in the Council’s suggested text for a partial general approach – ST-14484-2026-INIT/, the Minister needs to provide a rationale to the Irish people. These changes would eviscerate many of the social and agri-environment supports which exist in the Common Agricultural Policy. These changes would severely impact rural Ireland and too many of its farmers, at a time when we need to support both strongly.
DEFEND ARTICLE 10. Guarantee support for organic farming and agroecological transition.
REDISTRIBUTE CAP FUNDING FAIRLY. Protect smaller and disadvantaged farmers through mandatory support, capping and degressivity.
BUILD RESILIENT FOOD SYSTEMS. Direct CAP funding towards sustainable production, new entrants, local food systems and rural livelihoods.
We call on the Minister, Irish MEPs and European institutions to reject these amendments that undermine organic farming, weaken redistribution, remove essential guarantees for smaller and disadvantaged farms, and drop social conditionality completely.
A genuinely common CAP must deliver fair incomes, environmental responsibility, generational renewal and greater resilience in Europe’s food systems. Just when we need to support food sovereignty, local food systems, and our rapidly deteriorating environment, the Council seems hell bent on doing the exact opposite.
Below we outline exactly what the Council is proposing ahead of its meeting on 26th October, and what should be udone instead.
The Council proposes deleting Article 10(2), which explicitly requires Member States to support certified organic farming and extensive livestock production through both maintenance and transition measures. It also changes transition support under Article 10(1b) from mandatory to optional.
Although organic maintenance remains mentioned within mandatory management commitments, these changes remove important guarantees for organic conversion and wider agroecological transition.
TB demands: Restore Article 10(2), retain mandatory transition support, and strengthen provisions for landscape-level agroecological action and territorial food systems.
The Council introduces an exemption allowing Member States to avoid supporting environmental priority areas through the CAP where they demonstrate that national instruments already address them.
This risks weakening dedicated CAP support for organic farming and environmental measures.
TB demands: Remove or strictly limit this exemption, retain binding EU-wide environmental priorities, and ringfence at least 40% of CAP expenditure for agroecological, environmental and climate measures.
Mandatory degressivity and the proposed €100,000 cap remain unresolved in the Council text. Changes to payment differentiation also weaken the obligation to target farmers most in need.
TB demands: Mandatory degressivity beginning at €20,000, a €60,000 payment cap, and reinvestment of savings into smaller farms, new entrants and agroecological transition.
The Council changes the small-farmer payment from a requirement on Member States to an option, while retaining the proposed €3,000 maximum.
TB demands: Restore the mandatory scheme, increase the maximum payment to €5,000, and enable commercially active farms below one hectare to qualify.
The Council proposes making support for areas with natural or other specific constraints optional.
This risks weakening support for farming systems that sustain livelihoods, landscapes and communities in disadvantaged regions, particularly western Ireland.
TB demands: Retain mandatory ANC support and ensure extensive, low-input and high-nature-value farming systems remain viable.
Importantly, despite the recurring food, fertilizer, fossil fuel and other price and supply shocks, fair prices and market regulation remain largely unaddressed.
TB’s demands stronger farmgate prices, production-cost transparency, supply management or strategic food reserves. These objectives also require campaigning around the Common Market Organisation and related legislation.
National flexibility is increasing without equivalent accountability. The combination of optional interventions, discretion over environmental standards and unresolved redistributive rules could undermine a genuinely common CAP.
TB demands meaningful farmer and civil-society participation in CAP decision-making and debate, strong Commission oversight and sufficient dedicated funding.
Incredibly, the entire annex on social conditionality is set to be deleted under this council position. While ostensibly national labour laws should cover workers’ conditions, there is no logical reason to remove this extra layer of protection for what are in many cases the most vulnerable workers in society.
These are simply listed as SMRs (statutory mandatory requirements) and are compliant with existing laws. The existing EU labour directives would continue to apply, but breaches would no longer trigger the same dedicated CAP social-conditionality mechanism under the proposed framework.
TB demands the retention and strengthening of social conditionality in the CAP proposal
The next CAP must guarantee support for sustainable farming, not make it optional.
Talamh Beo is deeply concerned by amendments proposed in the Council Presidency’s partial general approach to the post-2027 Common Agricultural Policy (CAP).
The amendments weaken several important provisions in the European Commission’s original proposal, particularly those concerning organic farming, agroecological transition, redistribution of agricultural payments, price and market fairness for farmers, accountability, and support for smaller farmers and agri-food workers.
The underlying problem is a shift from mandatory European commitments towards greater national discretion. This risks perpetuating existing inequalities in agricultural support and undermining the transition towards resilient, environmentally sustainable food systems.
For Ireland, the consequences could be substantial. Smaller farms, extensive livestock systems, organic producers and new entrants need dependable support, not greater uncertainty about whether future governments will fund essential CAP interventions.
Notes to Editor
(The Council wording below identifies the operative text at issue. Proposed replacements are Talamh Beo’s )
ARTICLE / ANNEX | COUNCIL WORDING OR PROPOSED CHANGE | TALAMH BEO PREFERRED WORDING / AMENDMENT |
1. Article 10(1b), (2) | Article 10(1b): “Member States may provide support” for transition actions, including conversion to organic. Article 10(2), which required each Member State to support certified organic farming and extensive livestock under both forms of action, is deleted. Mandatory management commitments in Article 10(1a) still mention maintaining organic farming. | Restore Article 10(2) in full and change “may” to “shall” in Article 10(1b). Explicitly permit and fund whole-farm, collective and landscape-level agroecological transition and activities linked to territorial food chains. |
2. Article 4(2) | New exemption: “The obligation to provide support in a priority area … shall not apply where a Member State demonstrates in its NRP Plan the existence of national provisions or instruments that address that priority area.” Organic farming remains a priority in Article 4(1)(e). | Delete the exemption or require demonstrably equivalent, accessible and adequately financed measures. Guarantee dedicated organic and agroecological support and ringfence at least 40% of CAP expenditure for environmental, climate and agroecological measures. |
3. Article 6(2)–(4) | Payment differentiation is made more discretionary, weakening explicit targeting of farmers most in need. The degressivity schedule (25% above €20,000, 50% above €50,000, 75% above €75,000) and €100,000 cap remain in square brackets. | Require targeting of smaller, lower-income and active farmers. Adopt mandatory degressivity beginning at €20,000 and a €60,000 cap. Earmark savings for small farms, new entrants, Article 10 transition and territorial food-system support. |
4. Article 7(1) | “Member States may provide income support to small farmers”, replacing the Commission proposal’s “shall”. Annual payment ceiling remains €3,000. The scheme replaces specified other income-support interventions. | Restore “shall”; raise the annual maximum from €3,000 to €5,000. Permit commercially active producers below one hectare to qualify, using suitable output/sector criteria. Allow other legally compatible support without double funding. |
5. Article 8(1) | “Member States may provide support to compensate active farmers for natural or other area-specific constraints”, replacing the proposed mandatory requirement. | Replace “may” with “shall”. Preserve dependable ANC support for extensive, low-input and high-nature-value farms, especially in disadvantaged regions. |
6. Article 2(1)(a), 21a; CMO Regulation (EU) 1308/2013 | Article 2(1)(a) refers to “fair and sufficient income for farmers” and their position in the value chain. Article 21a refers to CMO competition rules. This text introduces no specific farmgate price floors, cost/margin transparency, supply management or strategic food reserves. This is chiefly a legislative gap, not a deletion. | Strengthen Article 2 to reference prices covering sustainable production costs and fair remuneration. Pursue parallel CMO and unfair-trading-practices reforms for price and margin transparency, below-cost purchasing safeguards, supply management and strategic reserves. |
7. Articles 2–4, 6–8; NRP governance provisions | Article 2 provides “non-binding CAP national recommendations”. Several provisions expand national discretion, including optional schemes and environmental exemptions, without corresponding binding participatory or oversight safeguards in this text. | Require meaningful consultation with small-farmer organisations, farmers and civil society in NRP design, implementation and review. Require public justification of departures from EU priorities, transparent monitoring, minimum standards, dedicated budgets and effective Commission scrutiny. |
8. Article 3(1), (3); Annex I, Part B | Council deletions remove Article 3’s reference to “the social conditionality system which comprises the statutory management requirements listed in Annex I, Part B” and related Part B references. Annex I Part B, “Rules on social conditionality”, is marked for deletion. Underlying labour law would still apply. | Restore Article 3’s social-conditionality references and retain Annex I, Part B. Make compliance with applicable working-condition and occupational-safety requirements a condition of relevant CAP payments, with effective, proportionate enforcement and penalties for serious or repeated breaches. |
The Council’s proposed amendments risk turning essential CAP commitments into discretionary national choices. Talamh Beo believes that the post-2027 CAP must instead provide dependable support for the farmers and farming systems needed to secure Europe’s environmental, economic and food-system resilience.
Ireland should defend a strong, common and redistributive CAP, with mandatory organic and agroecological transition support at its centre.
