The likely size of the CAP budget in the next MFF – reprise

The likely size of the CAP budget in the next programming period 2028-2034 has been highly contentious since the publication of the Commission’s MFF proposal last July. Among agricultural stakeholders, the AGRI Committee in the Parliament, and the AGRIFISH Council, the amount available for the CAP under its two Pillars in the current programming period was compared with the size of the minimum ring-fenced amount for CAP income support in the proposal and found wanting. The Commission, on the other hand, has insisted on the potential for a larger CAP budget depending on the choices made by Member States. In its most recent Fact Sheet ‘Unlocking synergies integrating EU funding for farming and rural communities’ published in January 2026, it claims “the EU budget in support to farmers and rural communities for 2028-2034 can be at the same level or even higher than the current CAP allocation 2021-2027”.

I have written several blog posts exploring the different factors that will influence the size of the future CAP budget. In July 2025, I wrote a post comparing the NRPF allocations to each Member State with the pre-allocated amounts they received under the six shared management funds in the 2021-2027 MFF period that will be replaced by the ‘single fund’ to determine winners and losers from the new NRPF allocation formula (to be precise, the relevant comparison is between the NRPF General Allocation and the six shared management funds this replaces, as Home Affairs was treated differently).

I followed this with a post in September 2025 that highlighted the big budget picture in which the Commission proposed an ambitious MFF budget of almost €2 trillion euro, but carefully calibrated so that the overall funding for the shared management funds that would be merged into the ‘single fund’ was maintained in current prices. The General Allocation in the NRP Fund, which replaces the shared management funds but excludes Home Affairs, would even see a tiny increase relative to the current allocation.

When the Commission published the minimum ring-fenced CAP amounts for income support in September 2025, this then allowed me to examine the structural space for countries to top up their minimum amounts by allocating additional funds from the overall NRPF allocation considering also their other ring-fencing obligations. In a post in October 2025, my conclusion was that Member States would have very different possibilities to add to their minimum CAP amounts. For some Member States it was clear that they would be unable to maintain their CAP budget at the current 2021-2027 level, even if for some other countries there would be the financial scope to increase the CAP budget if this was the political will.

Then in January 2026 the Commission President announced a concession that would allow Member States to free up some of the flexibility amount that would otherwise be unavailable for programming until the mid-term review of the national Plans, provided it was used for additional CAP interventions or measures dedicated to rural areas. The additional funding, which the Commission estimated at €45 billion, would increase the minimum CAP allocation by 15% or so if all Member States made use of this possibility. This makes a significant difference to the prospects for the CAP budget. In a post in January 2026 I estimated the likely increase in resources for the CAP for each Member State under this assumption.

This now provides the opportunity to redo the exercise in the October 2025 post taking account of these additional Mercosur amounts. In other words, we can ask about the structural space for countries to add to the Mercosur-amplified minimum ring-fenced CAP amounts from the unearmarked programmable resources to maintain CAP spending from Union funds in the next programming period at the same level in current prices as their pre-allocated amounts for the CAP in the current MFF period.

The overall NRPF budget

As a reminder, we start with Figure 1 which shows the size and share of the NRPF General Allocation in comparison to the overall MFF. The NRPF General Allocation equals the NRPF financial allocation for the NRP Plans less the minimum ring-fenced amount for Home Affairs. It merges the six shared management funds which are funded separately in the current CAP, including the two Pillars of the CAP, though it also has an additional objective to fund military mobility. We can thus make a direct comparison between the pre-allocated amounts for the six shared management funds and the General Allocation amount. Figure 1 shows that the Commission maintained the General Allocation amount at the same amount as previously allocated to the funds.

Member State NRPF allocations

That overall stability is not reflected in the NRPF allocations to individual Member States, due to the introduction of a new allocation key in Annex 1 of the NRPF Regulation. Figure 2 shows the percent changes in the NRPF General Allocation compared to the funding each Member State received for the six shared management funds it replaces in the current MFF. Countries to the left, including Czechia, Slovenia and Portugal, lose out under the new formula, while countries to the right of the graph, including some Central and European countries but also the Netherlands, Belgium and Luxembourg, gain.

The structural scope to increase CAP spending beyond the minimum ring-fenced amount

The scope for CAP spending within the NRPF allocations is determined by the amount of its NRPF allocation as well as its minimum ring-fenced amount for CAP income support. The structural scope to increase the CAP budget in a Member State beyond the minimum is determined by several factors apart from its overall NRPF allocation. These include the minimum ring-fenced amount for less developed regions in the Member State; the minimum ring-fenced amount for home affairs; and the size of the flexibility amount (which is 25% of the NRP Plan financial allocation less the minimum amount ring-fenced for CAP income support plus support for farm and forest investment).

The flexibility amount cannot be immediately programmed as it must be reserved, first, to fund compensation for natural disasters and then, at the mid-term review, funds can be released for programming including to address new priorities and challenges that may have arisen since the approval of the national Plans. I make the assumption that the minimum ring-fenced amounts for the CAP, less developed regions and home affairs must be programmed when the Plans are approved – otherwise there is no guarantee that the legal minimum ring-fenced amounts will be spent.

Funds held back in the flexibility amount cannot be immediately programmed but, if not required to fund damages from natural catastrophes, will become available for programming later in the programming period. Here, we must factor in the concession made by the Commission in January in the context of seeking approval to sign the Mercosur agreement. This allows Member States to use up to the two-thirds of the flexibility amount set aside to be programmed at the Mid-Term Review immediately if allocated to CAP interventions or for measures dedicated to rural areas. For simplicity, I refer to these as the Mercosur amounts in the rest of this post.

In what follows, I assume that all Member States will use this flexibility, and that the unfrozen funds will be used for CAP interventions including investments in rural areas. But for this reason, I also assume that there will be no additional funds forthcoming for CAP interventions when the remainder of the flexibility amount is unfrozen later in the programming period. There is no legal hindrance to doing so, so this assumption is made to make the subsequent number-crunching easier.

When these Mercosur amounts are added to the minimum ring-fenced CAP amounts, then several Member States would already have a CAP budget larger than the amounts pre-allocated to CAP Pillars 1 and 2 in 2021-2027. We ask the question, how much extra would the other Member States have to add to these Mercosur-amplified amounts to maintain their CAP budget at the current level? 

To get a sense of how constraining it will be for other Member States to find this money, we express the additional funding necessary as a percentage of the programmable NRP Fund resources that are not specifically earmarked for other purposes at the beginning of the Plan period. These unearmarked amounts can be calculated as the total NRP Plan financial allocation to a member state, less the minimum ring-fenced amount for CAP income support, less the minimum ring-fenced amount for less developed regions, less the minimum ring-fenced amount for home affairs, and less the amount required to be reserved for the flexibility amount.

At this point, we need to understand how the early mobilisation of the Mercosur amount will impact on the size of the flexibility amount that cannot be immediately programmed. Article 14(2) of the NRPF Regulation reads: “A flexibility amount, corresponding to 25% of the Union financial contribution of a Member State as set out in Annex I [allocation method], shall only be available for programming as follows: (a) Up to one fifth may be requested by a Member State in accordance with Article 34 (Amendment of the plan in case of crisis situations), with the remaining amount to be programmed in accordance with Article 25 (mid-term review); (b) three fifths may be requested by a Member State in accordance with Article 25 [midterm review] of which a part may be requested before the mid-term review in duly justified and exceptional circumstances;….”.

Member States can now request to mobilise the Mercosur amounts out of the tranche set aside to be released as part of the mid-term review, so presumably this will fall under the “duly justified and exceptional circumstances” exception in Article 14. This, however, does not exempt Member States from the need to fulfil this criterion and to set aside the full flexibility amount at the outset of the Plan. We continue with the assumption that the full flexibility amount must be earmarked at the outset of the Plan, even if the Mercosur amount will be available to add to the CAP budget at that point. The Mercosur amount will not impact on the unearmarked amounts that might be available to transfer additional amounts to the CAP.  

The outcome for Member States is shown in Figure 3. To the right are those countries where the Mercosur-amplified CAP amounts are already bigger than their current CAP receipts.

The blue bars show the percentages of the unearmarked programmable amounts that would have to be allocated in addition to the Mercosur-amplified CAP amounts to maintain CAP receipts at their current level in the other Member States. Countries that would be required to transfer, say, 40-60% or less of their unearmarked programmable amounts might find this relatively easy to do, whereas those countries that would have to transfer more than 60% might find this more difficult.

Croatia and Hungary are in a special category. The NRPF allocations to these countries are simply not big enough to enable them to meet their legal obligations to programme the specified minimum amounts for the CAP, less developed regions, home affairs and the 25% flexibility amount. I have no idea how the Commission plans to address this situation, but reducing the 25% figure for the flexibility amount would permit the circle to be squared.

Apart from these two countries where the situation is unknown, there are three countries that are unlikely to be able to maintain their CAP receipts at the current level, namely, Denmark, Austria, and Ireland. For all other Member States it will be feasible to maintain CAP spending at current levels and seven Member States already have a larger CAP budget without any further bargaining.

Conclusions

The size of the CAP budget will not be known until the national Plans are drafted and approved. In this post I examine the structural constraints on the ability of Member States to add to their minimum CAP ring-fenced amounts to at least maintain their CAP receipts at the same level as in the current 2021-2027 period. Whether these amounts will be transferred or not will depend on the political priorities that shape the national Plans.

My analysis assumes that all Member States will utilise the concession announced by President von der Leyen to mobilise part of the frozen money in the flexibility amount at the beginning of the Plan period provided it is used for CAP interventions or dedicated to rural areas. I assume that all of this funding is used to finance CAP interventions including those in favour of rural areas. On the other hand, I assume that no further transfers will be made to the CAP from the flexibility amount when resources are freed up at the mid-term review and later. We should also remember that the €6.3 billion in the Unity Safety Net to address market crises is not included in the figures above, while farmers can also receive support in the case of natural disasters from the flexibility amount, also not included in the figures above.

My assessment concurs with that of the Commission. Overall, the EU CAP budget will likely be similar to 2021-2027 in current prices and could even be greater, but with a different distribution across Member States. Denmark, Austria and Ireland will find it virtually impossible to maintain the same level of CAP receipts as under the current CAP. France, Luxembourg and Finland would need to transfer more than 50% of their unearmarked programmable resources but the political will may be there to do this. Other Member States would need to allocate less than 40% of their unearmarked programmable resources to maintain their CAP receipts, and there are seven Member States that will exceed their CAP budget in 2021-2027 assuming they are willing to transfer in full the Mercosur amount to the CAP.  

There is, of course, a very major caveat. This analysis is based on the Commission MFF proposal. It will remain valid only if the Council and Parliament keep the MFF budget at its proposed size. If the MFF budget is reduced, as must be deemed likely, the CAP budget will be also.

This post was written by Alan Matthews.

Photo credit: Images Money downloaded from Flickr and used under a CC by 2.0 licence.