The current system of receiving payment for entitlements will change greatly in the next CAP due to funding allocations for measures such as eco schemes, front-loading, Young Farmers’ Scheme and the National Reserve, before convergence is then enacted.

In this context, the current system of receiving payment on the number of entitlements a farmer possesses is relatively straightforward.

Change

But this is soon to change, with the new system coming in to place in 2023 under the CAP strategic plan for 2023-2027.

The Department of Agriculture recently released a draft consultation document which includes all of these changes, with the consultation phase closing on 8 December and the finalised document required to be submitted to the European Commission for approval by 1 January 2022.

Here’s how the changes will affect every farmer.

Starting position

Convergence is not a new phenomenon in terms of entitlement values. Under the current CAP, all entitlements held under the Basic Payment Scheme (BPS) were subject to convergence.

Essentially, farmers who held entitlements that had an initial unit value that was below 90% of the BPS national average saw the value of their entitlements increase during the period 2015 to 2019, while farmers who held entitlement values that had a unit value above the national average saw their unit values decrease. Entitlements with a value between 90% and 100% of the national average remained largely unchanged.

This process is known as convergence and it was set at 60% under the current CAP – ie all entitlements must have a value of at least 60% of the BPS national average (approximately €160, including Greening) by 2019. As the new CAP was delayed, entitlement values held in 2019 have rolled forward, with a minor adjustment due to budgetary changes related to Brexit.

This means that the provisional entitlement unit value in 2023 will be largely based on the 2022 payment entitlement unit value plus the Greening payment.

A small portion of the provisional 2023 payment entitlement unit value may be carried forward, as normally occurs, to fund aspects such as the EU crisis fund.

National ceiling cuts

Under the next CAP the BPS will be rebranded and be known as the Basic Income Support for Sustainability (BISS). The entitlement unit values will again be subject to convergence, with the proposal set at 85% convergence. However, before the level of convergence is calculated, funding is removed from entitlements and allocated to CRISS (front-loading), eco schemes and the Young Farmers’ Scheme (YFS).

CRISS

The Department of Agriculture has proposed to ringfence 10% of all direct payments to fund CRISS, which has become known as front-loading. This will establish a fund of €590m or a proposed allocation of €118.6m for each year from 2023 to 2027.

CRISS has become known as front-loading because of the payment mechanism. Money will be deducted from every entitlement value in the country but it will only be paid back out on a certain number of hectares.

Member states set their own maximum threshold and in Ireland’s case the Department’s draft consultation document states the plan is to select the minimum threshold of 30ha.

The reasoning given for this is as follows: “Following extensive modelling of various parameters, it was determined that 30 hectares was the optimum range of hectares to benefit the majority of farmers ie approximately 75% of farmers would benefit financially from the inclusion of CRISS at 30 hectares.”

The predicted average unit payment rate for CRISS is €43.14/ha (based on 2,750,000 eligible hectares or 60.9% of utilisable agricultural area) with a minimum and maximum payment level of €40.98/ha and €45.29/ha proposed. Department figures for 2019 show that approximately 67,000 farmers had a farm size of less than 30ha while 55,000 farmers had a farm size in excess of 30ha.

To determine if you will benefit or lose from CRISS, you need to know the starting value of entitlements in 2023 and the area of land eligible. We can look at some examples to explain this further.

Examples

A farmer with 50ha and 50 entitlements with an average value of €360 in 2023 will contribute approximately €1,800 (50 entitlements x €36 per entitlement) to the fund, while the maximum they can recoup is €1,294.20 (30ha x €43.14/ha). Therefore they will be a net contributor to the tune of €505.80.

The same scenario can be present for a farmer with less than 30 hectares but with high-value entitlements. Take for example a farmer with 23 entitlements worth €650 in 2023. This farmer will contribute €65 of every entitlement to CRISS but he will only recoup €43.14 on each eligible hectare and entitlement.

In contrast, take two farmers with entitlements in the region of the national average with a value of €260 farming 29ha and 49ha respectively. Farmer A, with the lower hectares will contribute €754 and recoup €1,251.06 while Farmer B will contribute €1,274 and recoup a maximum of €1,294.20.

Eco schemes

Eco schemes were covered in detail in week one of the CAP series. They will also form a massive component of direct payments under the next CAP. It is proposed that 25% of the value of each entitlement unit will be ringfenced to fund the national allocation, or some €296.5m per annum.

In contrast to CRISS, there is no minimum or maximum number of hectares that a farmer can receive payment on. Also, for CRISS a farmer must possess an eligible hectare to activate the entitlement on.

Under eco schemes, the level of funding a farmer contributes is based on 25% of the number of entitlements they possess.

However, the eco schemes payment will be paid on so-called naked hectares (eligible forage hectares that a farmer does not have entitlements for) and also on ground which has previously not been deemed eligible such as scrub, groves of trees etc.

Therefore, some farmers will have a better chance of receiving a higher payment.

Winners and losers

There will also be farmers who will benefit and those who will lose out depending on the value of their entitlements and also on the eco schemes payment rate for hectare.

If every hectare of eligible ground was included in eco schemes, the payment would be in the region of €64/ha.

However, the Department predicts that 15% of eligible farmers will not participate and so that payment will be based on 3,993,868ha, delivering a proposed payment of €74/ha per annum.

If only 50% of farmers participate, then the payment will be maxed out at the highest rate possible of €126/ha per annum.

Determining if you are a net contributor or beneficiary can be carried out in a similar manner as for CRISS without the limitation on payment being based on 30ha.

If we take a farmer again with an entitlement worth €260 farming 29ha, they will contribute €65/ha or €1,885 in total. Under the Department’s prediction of an 85% participation rate, they will receive a payment of €2,146 or be a net beneficiary to the tune of €261.

A similar size farm but with an entitlement value of €400 will contribute €100/ha or €2,900 to the fund and only recoup €2,146, meaning that farmers with higher-value entitlements will in general be net contributors unless they have naked area to draw down payments on or the participation rate is lower than expected and payments rates are set at a higher figure.

Support for young farmers

Every farmer with entitlements will contribute to a fund to support young farmers which will be known as the Coupled Income Support for Young Farmers (CIS-YF). This measure will harvest 3% of the value of every entitlement to fund a national envelope worth in the region of €178.5m over the period 2023 to 2027. The proposed support under CIS-YF is outlined in the draft consultation document at €178/ha to a maximum of 50ha.

Minimum and maximum payment rates of €165/ha and €190/ha, respectively, will be in place to allow for flexibility to accommodate a higher or lower number of applicants annually.

It is predicted that the financial allocation under CIS-YF will be adequate to meet the Department’s target of 4.89% of total utilisable agricultural area and is based on an average of 33ha per successful beneficiary (based on YFS allocations 2015-2020).

BISS and convergence

The value of the entitlement remaining after removing 38% of its value (25% eco schemes, 10% CRISS and 3% CIS-YF) is what will be left to calculate the future BPS payment after one more final cut is made.

It is proposed to ringfence 3% of the national BISS value to fund a National Reserve scheme on an annual basis.

The Department’s calculations outline that in the region of €4m will be redirected to fund the National Reserve, with the remaining annual financial allocation for BISS outlined at €728,494,838 per annum or approximately €3.64bn for the period 2023-2027.

The planned average unit amount under this intervention is €164.39 per payment per activated entitlement. This is based on an expected number of 4,407,042 activated payment entitlements, with the annual financial allocation of €728,494,838 expected to support 97.6% of utilised agricultural area.

The remaining value of each entitlement will be subject to convergence, which is proposed at 85%. This means that all payment entitlements will have a value of at least 85% of the planned average unit amount i.e. 85% of €164.39 (€139.73) by 2026.

The amount by which an entitlement reduces or increases each year between 2023 and 2027 will be determined by a coefficient decided by the European Commission.

Calculations on how convergence will affect entitlements each year cannot be carried out until this information is available.

Wider reaching consequences

All of the measures described here will have direct consequences for your direct payments.

They may also have big implications for entitlements currently involved in long-term leases or for future agreements.

While the changing value of entitlements could also change how the sale of entitlements are viewed.

This is without taking in to account other measures currently being considered for entitlement trading.

Online calculator

The Irish Farmers Journal has developed an online calculator which shows how the value of your entitlements will be affected by funding allocated to eco schemes, CRISS, the YFS and the National Reserve along with determining the starting entitlement unit values under BISS. Click here to access the calculator.