How I Used ChatGPT to Understand the CAP Simplification Package — and Why It Changed How I Think About EU Lawmaking in 2025

Paul Shotton, PhD

Co-Founder Advocacy Academy, Advocacy Strategy and Owner at Paul Shotton Consulting

May 22, 2025

What simplification, omnibus packages, and strategy-driven policymaking really mean — and how public affairs needs to adapt.

Over the past few months, we’ve been giving regular presentations on the 2025 European Commission Work Programme. One thing that stands out this year is the number of non-legislative and simplification initiatives. Not just new strategies like the Single Market Strategy, EU Water Resilience Strategy or the Startup & Scale-Up Strategy, but also a growing list of simplification and omnibus packages that will impact existing laws well ahead of their usual revision cycles.

That prompted a reflection of my own. I realised that while I understood these initiatives conceptually, I hadn't worked closely on a simplification package myself. I wasn’t entirely clear on how they translated into actual legislative change, particularly in relation to amendments to base acts or how they were supported through delegated or implementing acts. I also had limited visibility on how these new initiatives overlap with or short-circuit traditional policy cycles.

That became particularly relevant during a workshop with a client. They were exploring whether the CAP Simplification Package could offer a route to accelerate improvements to their own regulatory environment — outside of their sector’s formal review process. I saw the potential logic, but I couldn't fully assess the strategy's feasibility without a deeper understanding of how the CAP package worked. I needed to know: was this just administrative streamlining, or a real opportunity to reshape legislation?

What also became clear as I worked through this is that many of these tools — simplification packages, omnibus proposals, delegated acts — are still not well understood in practice by many public affairs teams. These newer mechanisms often operate faster, cut across portfolios, and don’t follow the usual process. They’re increasingly central to how change happens in VdL Brussels, but they still sit just outside the standard playbook. And given how quickly they’ve become common — especially over the past couple of years — I think there’s a wider need to get to grips with how they work if we’re going to spot opportunities and shape outcomes early enough.

So I set aside some time to work through the process.

What the CAP Package Actually Is

The CAP Simplification Package is a legislative proposal adopted in May 2025. It amends both the CAP Strategic Plan Regulation (EU 2021/2115) and the Horizontal Regulation (EU 2021/2116). It’s grounded in Article 43(2) TFEU and follows the ordinary legislative procedure, meaning full co-decision by the Parliament and Council.

It is backed by a Staff Working Document, a stakeholder survey of over 27,000 farmers, a political framing via the Vision for Agriculture and Food (February 2025), and is part of the broader Better Regulation and Competitiveness agendas.

The contents go well beyond technical adjustments:

• New crisis payments under direct and rural development funding

• Revisions to conditionality requirements (GAECs)

• More flexible small farmer payments

• Elimination of the annual performance clearance mechanism

• Streamlined processes for amending national CAP Strategic Plans

It’s a full legislative revision — just not labelled as one.

Mapping the Process

To understand how this came together, I worked through the text, the roadmap, Staff Working Document, and Q&A published by the Commission.

Here’s how the policy process unfolded:

1. Political framing through the Vision for Agriculture and farmer protests

2. Stakeholder input gathered through targeted surveys, dialogues, and thematic groups

3. Commission drafting and interservice consultation (early 2025)

4. Adoption by the College in May 2025

5. Legislative proposal sent to Parliament and Council for co-decision

6. Parallel delegated and implementing acts planned for Q3–Q4 2025

7. Member States invited to amend CAP Strategic Plans using the new flexibilities

This revealed a layered and iterative process. The legislative proposal is only part of it. Much of the substance will be implemented through delegated or implementing acts — with additional changes planned for later this year.

It also made one thing painfully clear: by the time these proposals appear in the Work Programme, a significant window for influencing the core content has already passed. The real action is often in the early drafting process — inside DG AGRI and the Secretariat-General — where decisions are made about what gets included, left out, or repackaged as a simplification. For advocacy to be effective, it needs to happen during that early internal process, long before the file is public.

Using ChatGPT to Work Through It

What made this manageable was the use of ChatGPT. I uploaded all the core documents and used it to:

• Clarify the legal basis and identify affected legislative acts

• Map the timeline and sequencing of the reform

• Understand the interplay between legislative, delegated, and implementing acts

• Identify where advocacy or engagement would have influence

I didn’t use it to write content or produce finished outputs. I used it as a thinking tool — to ask questions, break down documents, cross-reference sources, and save time piecing everything together.

What it allowed was quicker iteration: checking assumptions, getting structured summaries, and zooming in on institutional mechanics that might otherwise take hours to extract from legal texts or working documents.

Why This Matters More Broadly in 2025

The CAP package isn’t an isolated case. The 2025 Work Programme is full of similar initiatives:

• Omnibus Packages:

• Simplification Packages:

• Strategic Communications and Roadmaps:

Each of these may begin as a non-legislative initiative, but they can evolve into amendments to base legislation and regulatory adjustments via implementing acts. The Commission’s new tools (implementation dialogues, stress testing, SME competitiveness filters) create new pathways for influence — often well before a formal proposal is tabled.

Final Reflections

This was an interesting exercise not just because I learned more about the CAP file, but because it forced me to look again at how legislation is now developed and revised in the EU. The process is no longer limited to formal evaluation cycles or green papers. Instead, it often runs through overlapping initiatives labelled as simplification, competitiveness, or digitalisation.

For those working in public affairs, that raises two questions:

• Are we spotting the right opportunities early enough?

• Do we really understand how these hybrid tools work?

I still think formal review cycles matter. But I also think the real action is shifting earlier and deeper into Commission process. Tools like ChatGPT are never a substitute for expertise or experience, but they can help accelerate our understanding and decision-making in this evolving environment.

If you're also working through these files or trying to figure out where to focus, happy to connect and compare notes.