CAP 2023-2027: new BCAM 1 requirements that may reduce your agricultural payments

Key data

Farmers and livestock producers covered by CAP 2023-2027 are facing a regulatory change with retroactive effect: Delegated Regulation (EU) 2026/177, published on 26 March 2026 but with entry into force on 21 January 2026, adjusts the requirements of the BCAM 1 standard (good agricultural and environmental conditions). Non-compliance with this standard may result in a reduction of the direct payments received by the holding.

This regulation amends Delegated Regulation (EU) 2022/126, which in turn supplements Regulation (EU) 2021/2115, the central legislative framework of the CAP for the 2023-2027 period. This is not an entirely new regulation: it is a targeted amendment to the proportions and criteria of BCAM 1 that were already in force.

What does this regulation establish?

The regulation acts on two specific elements of Delegated Regulation (EU) 2022/126:

• Additional requirements for intervention types specified by Member States in their CAP strategic plans.
• Proportions and criteria of the BCAM 1 standard, which governs the good agricultural and environmental conditions that holdings must maintain to be eligible for direct payments.

The BCAM 1 standard is one of the enhanced conditionalities of CAP 2023-2027. Compliance with it is a prerequisite for accessing direct payments. Member States have some flexibility in defining how they apply these standards in their national strategic plans, but must do so within the limits set by European legislation.

The exact technical details of the new proportions can be found in the full text of the Delegated Regulation (EU) 2026/177 on EUR-Lex.

Economic and operational impact

The economic impact of this regulation is not measured in a direct tax or cost, but in the risk of payment reductions. CAP direct payments represent a substantial part of the income of many Spanish agricultural holdings. Non-compliance with the BCAM 1 standard can trigger penalties that reduce those payments.

At an operational level, the changes involve:

• Review of land management practices to verify that they meet the new BCAM 1 proportion criteria.
• Adaptation of the Spanish national strategic plan by the authorities, which may translate into new specific requirements for holdings.
• Coordination with the autonomous communities, which are responsible for managing and monitoring CAP compliance in Spain.

The cost of adaptation will depend on how far each holding's current practices diverge from the new criteria. Holdings that already strictly complied with the previous BCAM 1 may not need significant changes. Those operating at the edge of compliance are the ones that bear the greatest risk.

Who is affected?

• Farmers holding agricultural holdings covered by CAP 2023-2027 direct payments.
• Livestock producers with land subject to CAP conditionalities.
• Agricultural holding owners receiving any type of aid linked to compliance with BCAM standards.
• Agricultural advisors and agencies specialising in CAP, who must update their knowledge of the new criteria in order to correctly advise their clients.
• Autonomous communities and paying agencies in Spain, which must adapt their controls and the national strategic plan.

Practical example

A farmer in Castilla-La Mancha with a dryland cereal holding receives CAP direct payments linked to compliance with BCAM standards. Until now, their land management complied with the BCAM 1 criteria under Delegated Regulation (EU) 2022/126.

With the entry into force of Regulation 2026/177 on 21 January 2026, the proportions and criteria of BCAM 1 have changed. If the autonomous community, when adapting the national strategic plan, determines that the holding no longer meets the new proportion criteria, that farmer could face a reduction in their direct payments in the next settlement.

The recommended immediate action is to contact the agriculture department of their autonomous community to find out how the change has been transposed in Spain and to verify whether their holding needs adjustments before the next CAP declaration.

What should businesses do now?

1. Identify whether your holding is covered by CAP 2023-2027 and whether you receive direct payments linked to compliance with BCAM standards.
2. Consult with the agriculture department of your autonomous community to find out how Spain is adapting its national strategic plan to the new criteria of Regulation 2026/177.
3. Review the current land management practices of your holding and compare them with the new BCAM 1 standard criteria once the Spanish transposition has been published.
4. Update the holding's documentation to demonstrate compliance with the new requirements before the next CAP declaration.
5. Consult with your agricultural advisor or CAP-specialised agency to assess whether the changes in BCAM 1 proportions affect your specific situation and whether there is a risk of payment reduction.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R0177