Ioannis Kaimakamis

I have lived the CAP from four angles that rarely sit in the same room.

First, as a farm operator, where CAP rules are not “policy”; they are daily constraints, cash-flow timing, and operational risk. Second, as a private-sector strategist/advisor, translating CAP incentives and restrictions into investable plans (or recognising when they are not). Third, as a research-trained animal-industry professional, I am always asking what the system actually rewards versus what it claims to reward. And fourth, more recently, and more uncomfortably, but decisively, through the paying-agency lens, from the side of implementation and controls, having served as Executive Vice President of the Board of OPEKEPE. 

That “fourth angle” is the one that makes the New Delivery Model (NDM) impossible to romanticise.

Because the NDM is not an abstract reform, it is a bet that Europe can move the CAP from rule compliance to performance delivery and that Member States can build the administrative, data, and control infrastructure to demonstrate it in practice. 

What the NDM promised strategically, not rhetorically

At the EU level, the NDM is anchored in a simple logic:

1. Member States design CAP Strategic Plans (one framework across pillars, one intervention logic, and one performance story).  
2. Delivery is tracked through a Performance Monitoring and Evaluation Framework (PMEF) with standard indicators.  
3. The system operationalises performance through Annual Performance Reports (APR), in which reported spending must align with declared outputs/results, and where discrepancies become a control-and-correction issue, not a “nice-to-have” evaluation exercise.  

In other words: Europe is buying demonstrated delivery, not just declared participation.

This is why I keep insisting that the next CAP era will increasingly reward those who can run documentation discipline + data flows + audit readiness as part of farming itself, an argument I developed more concretely through the “MRV” lens in Carbon Payments = Data Payments. 

Where Greece struggles: the gap between “plan” and “operating capability”

Based on the responses I provided in April 2025 to the study questionnaire titled “Study on CAP Governance and the New Delivery Model for CAP 2023-2027” (and, frankly, on what the sector experiences), Greece did not primarily fail in “intent.” It struggled with translation, moving from EU architecture to a functioning national operating system.

1) Strategy design became procedural, not transformative

The Strategic Plan process included the expected elements: SWOT, consultations, ex-ante logic, and stakeholder participation. Yet too often these became format compliance rather than a hard, national strategic choice. Which production systems do we want to scale, which risks do we want to insure, and what “performance” means in Greek agriculture beyond checklists?

The result is that the plan can look “complete” on paper while remaining weak as a transformation instrument, especially for livestock, where disease risk, feed volatility, labour scarcity, and financing constraints are structural rather than cyclical.

This is exactly why I have repeatedly argued that “resilience” cannot be treated as a slogan or an eco-scheme label; it must be treated as an operational doctrine with measurable farm KPIs and crisis-response capacity. 

2) Coherence across Pillar I and Pillar II is still more aspiration than reality

The NDM’s promise of coherence runs into familiar Greek friction: different administrative rhythms, fragmented IT, and interventions that overlap without delivering a unified behavioural signal.

This is not a technicality. When interventions overlap while controls remain heavy, the system unintentionally selects for:

• actors who can absorb transaction costs,
• actors who can “navigate” complexity,
• actors who can outsource compliance
  rather than those who deliver the highest productivity, innovation, or environmental performance per euro.

3) Complexity is no longer “annoying”; it is economically selective

Eco-schemes and conditionalities are often discussed in terms of environmental ambition. On the ground, they are also selection mechanisms: they determine who can participate, who gives up, and who gets penalised.

This is why the NDM if not matched with simplification and smart control design can become a machine that produces:

• higher administrative burden,
• higher error risk,
• higher fear of sanctions,
• lower participation by smaller or less-organised farms,
  and therefore lower real-world impact.

The same political economy dynamic appears in the debate around “genuine farmers,” eligibility rules, and the risk of punishing the wrong category of rural households. 

The paying-agency reality: performance is built with systems, not declarations

From the paying-agency side, the NDM changes the job description.

It is no longer enough to “pay correctly.” You must also prove that the payment corresponds to a defined output, that controls are defensible, that data flows are consistent, and that audit trails can survive external scrutiny. 

That creates three hard realities:

1. IT becomes policy. If your systems cannot connect declarations, registries, invoices, geo-data, animal databases, and controls, then the policy does not exist operationally—only administratively.
2. Controls become the bottleneck. A performance model without risk-based, proportional controls becomes a queue generator.
3. Implementation costs rise structurally. Not because people are inefficient, but because the model demands more reporting, more cross-checks, more evidence.

This is exactly the compliance-cost argument I emphasised in my questionnaire responses back in April 2025: the NDM’s burden is not merely “paperwork.” It is a structural burden on administrations and paying agencies, especially when they were not resourced as if they were building a new operating system.

A concrete preview of where this is heading: MRV logic is already here

If you want to see the NDM future in one intervention, look at MRV.

The “carbon” discussion is often framed as a matter of climate ideology. In practice, the real centre of gravity is Measurement-Reporting-Verification: registries, invoices, logs, advisor attestations, software-generated reports, and audit readiness. That is not a side detail; it is the product being subsidised. 

And if MRV becomes normalised in arable interventions, livestock will not remain untouched for long. The direction is clear: emissions intensity, performance metrics per kg output, and evidence chains that can be verified.

The missing bridge: AKIS as the performance infrastructure (not a box to tick)

If “performance” is the aim, then knowledge transfer is not a peripheral theme; it is infrastructure.

That is why AKIS, especially as it becomes linked to eligibility and coupled support, cannot be treated as bureaucratic theatre. In the OpenAI era, farmers already have access to “good enough” advice instantly; if Greece does not feed its own knowledge into usable advisory protocols and data ecosystems, the country will remain dependent on generic models not trained on Greek reality. 

AKIS done seriously means:

• turning research into farm protocols and checklists with measurable indicators,
• redefining the advisor role from “paperwork handler” to performance partner,
• building structured farm datasets that can improve both advisory quality and policy design.

Without that, the NDM becomes a control-and-reporting machine without a learning engine.

What I would change practically, not conceptually

If Greece wants the NDM to work as intended, the upgrade is not a speech. It is a build.

1. Design interventions around operational segments. Stop pretending “one complexity level fits all.” Create tiers by farm type, scale, and risk profile, with proportional evidence requirements.
2. Move to a single-source-of-truth data architecture. If data are scattered across non-connected systems, the NDM will remain slow and error-prone by construction.
3. Institutionalise risk-based controls. Audits should concentrate where risk is highest, not where rules are most straightforward to check.
4. Could you add a real crisis-response module? Livestock does not survive on delayed payments and post-factum announcements. It needs fast, rule-based support activation when disease or climate shocks hit.
5. Treat MRV capacity as a competitiveness issue. The farms that will dominate the next CAP phase are those that can demonstrate performance, environmental delivery, and animal health discipline with auditable evidence.  

Closing thought

The New Delivery Model is not failing because Europe chose “performance.” Performance is the right direction.

It struggles when Member States treat it as a regulatory update instead of what it truly is: a new operating system for how money is justified, controlled, and connected to outcomes.

Greece does not need more slogans about simplification, digitisation, or resilience. It needs the unglamorous build: systems, data architecture, proportional controls, AKIS that works, and institutions that can respond in time- so that performance stops being a paragraph in a plan and becomes the way the sector actually runs.

Further reading on Kaimakamis.com

• Carbon Payments = Data Payments (MRV as the real policy product)  
• Beef finishing in Greece: why the entry price decides the margin (two-price system logic)  
• Reading Sheep Pox as a System: Four Transmission Patterns, Four Policy Packages  
• Sheep pox, movement bans and transaction costs  
• Pluriactive Farmers, Eligibility Rules and the Political Economy of CAP Direct Payments  
• AKIS as a precondition for coupled support in Greek livestock farming  
• Resilient Livestock Farming in Practice – no more “business as usual”