To advance animal welfare, FOUR PAWS introduces the idea of an animal welfare benchmark to be introduced in the next CAP (for the funding period 2028-2034). An idea widely supported among the animal welfare movement.  

The idea was born out of the need to reconcile three issues, traditionally seen as being at odds: 1) the need to reform EU husbandry to improve on-farm animal welfare standards; 2) the significant costs of such transformation; and 3) the economic viability of farmers during and after this transition. 

The solutions we propose are elaborated in our report “The Gap in the CAP”. The first part suggests ways to optimise the tools that already exist in the CAP (Eco schemes, VCS, etc.), while the second presents a new CAP-tool: the animal welfare benchmark, object of this letter. 

Such increased CAP support towards enhanced animal welfare standards on EU farms conforms to legal requirements (Article 13 TFEU), social demand (Eurobarometer 533, 2023), health obligations (EU Action on AMR) and financial rebalancing (while livestock represents 40% of agricultural output, the percentage of CAP funds dedicated to animal welfare is very limited - see IEEP’s report on how animal welfare is supported via the CAP, June 2025).  

Presentation of the animal welfare benchmark (or “AW benchmark):  

The AW benchmark consists of a shared and transparent roadmap enabling a structured transition, via an incremental approach, with all farmers heading over time towards a common horizon of legal standards fixed in (for instance) 2050.  

Why? The raison d’être, a holistic approach  

Without a shared target, regulations and subsidies can pull in different directions, undermining each other’s efficiency. The benchmark, on the contrary, offers a holistic approach, providing a shared target or synergy between EU policies and fundings. The multi-year roadmap of incremental standards would ensure every CAP instrument advances towards the same end-goal.  

How? Design of the benchmark

Five main elements should be considered for the benchmark to be optimal: 

A legitimate panel 

The target of the benchmark needs to be defined – but by whom? FOUR PAWS suggests the setting up of a panel which, to be legitimate, needs to be: 

• Rigorous: it must be made up of experts (scientists; technical experts) and representatives of civil society for a fair representation of all interests at stake;
• Democratically owned: to come with broad ownership, we propose a panel appointed by the European Commission and confirmed by the European Parliament, for democratic backing;
• Ambitious: the standards must be ambitious enough to avoid revision or overhaul after 5 or 10 years (otherwise, it would lose one of its main qualities: predictability).

Legal and financial coherence 

Article 13 TFEU requires animal welfare to be mainstreamed in any piece of agriculture legislation (incl. CAP) that could affect animal welfare. Hence, an “art. 13 check” should be included in legislative procedures (especially in the Commission’s impact assessments or the RSB’s reviews) and financial streams (to avoid contradictory incentives and ensure subsidies follow the roadmap). 

Degressive support to steer change 

Early adopters are the ones bearing the most risks (upfront costs, longer return on investment, technical/market uncertainty). Hence, one must ensure it is economically viable for pioneer farms to move early by offering them higher compensation. This way, pioneers are fully compensated, leadership is rewarded, and with subsidies decreasing as the legal deadline nears, late adopters receive support, although to a lesser extent to not overpay them. 

Continuous (or “cross-CAP-period") support 

As new animal welfare rules come with multi-year transition periods which sometimes extend beyond the 7-year CAP period, we need support to also extend beyond CAP periods if necessary, with no breaks in support during the transition, to ensure structural changes (e.g. barns) are supported seamlessly.  

Development of welfare monitoring systems 

The benchmark, being an outcome-oriented policy with a focus on result, will require clear and science-based animal welfare indicators to assess and ensure progress over time. Such indicators are being researched and developed, as EFSA, the EU Animal Welfare Platform and DG SANTE all work on refining indicators per species. The potential of those indicators is vast, especially with new technology which opens the fields of possibilities: they will assess progress but also offer opportunities for farmers (e.g. easy collection of data (reducing bureaucracy), optimisation of time and resources, earlier detection of disease/abnormal behavior, etc.).  

To summarise:

As the AW benchmark is (1) economically viable, (2) logistically feasible, (3) democratically backed and (4) scientifically grounded, it is the way forward to drive real and necessary change in EU animal husbandry, without compromising the sector’s profitability. The numerous advantages, besides improving animal welfare, address most farmers’ concerns. The benchmark would indeed provide 

• system coherence, mutual reinforcement of policies and funds, thus enhanced efficiency;
• a spread of the transition costs over the years/decades;
• homogenisation of the EU level-playing field as all farmers head towards the same standards;
• flexibility (1) as farmers can opt-in the transition process when they feel ready and (2) the outcome-oriented policy focuses on results, rather than processes;
• predictability, hence reassurance on investments for farmers and investors;
• incentives for research (due to foreseeable return on investment).

It would further favour generational renewal: transforming the livestock sector into a sustainable, future-proof one will attract young farmers to take over the reins.  

Finally, it would guide and attract private funding, given the growing demand from investors to invest in sustainable practices. One example is the Business Benchmark on Farm Animal Welfare (BBFAW), which FOUR PAWS supports as a funding partner. Convening institutional investors representing $2.8 trillion in assets, the BBFAW’s global investors underscore that investing in the welfare of farm animal addresses business risks and offers opportunities (with direct implications for long-term value creation in the food sector). In this regard, the AW benchmark would offer a credible framework for steering private investments and practices; it would not only support farmers and policymakers, but also attract investors by providing a coherent, forward-looking regulation that fosters sustainable agriculture. 

NOW is the time for a SIMPLE ask: the relevance for the CAP 2028-2034 reform 

Given the relevance of our proposal to the EU’s priorities and the multiple benefits, FOUR PAWS asks European policymakers to insert, in the legislative proposal for the next CAP 2028-2034, a legal provision providing a framework, or at least a legal basis, for the future development of the AW benchmark described in this letter.  

Timing is crucial here, for two main reasons: 

• With the upcoming modernisation of the animal welfare legislation, the benchmark would synchronise funding streams to help farmers implement the new legal standards before they become mandatory; it would actively support the legal reforms, making them more implementable.
• By providing a dedicated mechanism to assist farmers in transitioning to higher welfare systems, the way will be paved for new animal welfare legislation that, thanks to Article XX of GATT, is one of the only routes to providing conditionality on imports requirements, as demanded by Europe’s farmers.

The animal welfare benchmark therefore offers a pragmatic tool to support farmers through the transition, align CAP funding with upcoming legal reforms, and strengthen the EU’s ability to uphold higher welfare standards both domestically and in trade.