12 August 2026

Tracking changes in Good Agricultural Practice Regulations since 2018

Signalling considerable changes to requirements for farming practice, Eddie Burgess, Agricultural Catchments Programme, provides an overview of the more significant changes since the introduction of the fourth Nitrates Action Programme in 2018.

The EC Nitrates Directive was given legal effect in Ireland under its first Nitrates Action Programme (NAP) in 2006 with the introduction of the Good Agricultural Practice (GAP) Regulations, Statutory Instrument (S.I.) number 788 of 2005.

The Nitrates Directive requires a review of the NAP at least every four years, which has resulted in revised Nitrates Action Programmes. We are currently in the sixth NAP and GAP reg. S.I. 588 of 2025 came into effect on the 1^st of January 2026, running for three years, until 2028.

The principal elements of the NAP include:

Limits on farm stocking rates
Limits for nitrogen and phosphorus application rates
Prohibited spreading periods for applying organic and chemical fertilisers
Minimum storage requirements for livestock manures
Set-back distances from waters.

The Nitrates Directive stipulates a 170 kg per hectare livestock manure nitrogen limit. However, Ireland and other EU member states have availed of a derogation to this. There has been an increased focus on the impact of this derogation in the current and two previous NAPs. Consequently, in 2020, the Irish government undertook a review of the Derogation mid-way through the fourth NAP. The EC also requested a mid-term derogation review in the fifth NAP.

Changed requirements

Considerable changes to requirements for farming practice have resulted from these NAP reviews. The ‘Timeline’ below gives an overview of the more significant changes since the introduction of the fourth NAP in 2018. Please note, this is not a definitive outline of GAP requirements and should not be used for this purpose. Rather, it is a simplified synopsis of most relevant changes introduced through the regulation revisions.

4th NAP – 2018

Maximum Soil Sample area 5 ha, every 4 years (was 8 ha every 5 yrs)
Nutrient Management Programme simplification – previous year’s SR used to determine chemical N & P grassland allowance
170 N limit calculation for Imported livestock manure based on the previous year’s SR
Autumn P allowed on winter cereals up to 31^st October
Increase P allowance for OSR
Changes to chemical N & P grassland allowances:
- Extra P build up allowance on index 1 & 2 soils and reduced limits for N and P index 3 & 4
- Increased KT – Training requirements & ASSAP
Green cover requirement after a non-selective herbicide reduced to 75% of contracted area (crops for seed or human consumption)
Excess P allowance for Pig manure to be phased out by 2021 and ceased for Poultry and Mushroom manure
Storage capacity requirements and closed periods have NOT changed

Derogation

Increased sanction when manure storage capacity is insufficient – Derogation rejection
50% Slurry to be spread by 15 June & LESS to be used for any applications after then

2-Year Derogation Review – changes in 2020 for derogation farms

New Training Requirements
Nutrient Management and Sustainable Farming
Grass Budget or grass management course
Hedgerow Biodiversity requirement:
- One mature whitethorn/ hedgerow
- Three-year cutting cycle
1.5 kg/ha clover in grassland reseeds
170 kg N/ha limit for Commonage
Lime requirement & programme
LESS for all slurry spread after 15^th April

2-Year Derogation Review – changes in 2021

N excretion rate increases for dairy cow 85kg to 89kg
Roadways to camber away from watercourses

Farms with Grassland Stocking rate (GSR) > 170

Max. 15% protein in concentrates when grazing
4-year liming programme required
Use LESS from 15^th of April
Restrict Cattle access to water courses
- No direct drinking points
- Fence 1.5m from watercourse
- Water trough located >20m from water

Changes in 2022

Introduction of closed period for soiled water on dairy farms – 21^st to 31^st December
Longer closed period slurry – all slurry must be spread by 8^th October
The prohibited period for chemical fertiliser extended by approximately two weeks
Max. 15% protein concentrates for grazing dairy cows or 2 Y.O. cattle on farms with GSR > 130
Commonage ground: Max SR of 50kg N/ha & no chemical N allowed
A 10% reduction in chemical N on grassland & new chemical N limit on farms with GSR < 130
P Index 4 assumed if no soil test available for farms with GSR > 170 kg N/ ha.
P index 3 recommendations are the maximum allowance for 20% + OM soils
Introduction of a slurry movements notification system
Use LESS for all slurry on farms with GSR above 170 kg N/ ha
6m minimum buffer for late harvested crops on intersecting watercourses
Green cover establishment required immediately after harvest
New N & P values for cattle slurry and broiler manure
Allowance for extra P application from Pig manure no longer exists

Derogation

Plough grass only – March-May
10% inspections (up from 5%)
Non-compliant derogation farms are not eligible for both the current & following year.
Organic Manure movement notification deadline of 31 October introduced

Changes in 2023

P index 4 if no soil test on arable land & farms with GSR > 130 kg N/ ha.
Max 15% CP in concentrates fed to grazing livestock for farms with GSR >130
Soiled Water closed period extended to 21 days – 10^th to 31^st December & 3-week storage capacity required on dairy farms
All slurry spread by 1^st October
Use LESS on farms with GSR above 150 kg N/ ha, for all pig slurry and on arable land if not incorporated within 24 hours
N banding – Cow N excretion rate dependant on milk yield: 80kg, 92kg or 106kg
Fertiliser purchases register
Chemical N closed period extended by 14 days
3m buffer for chemical fertiliser (previously 2m)
Tillage Buffer Strips increase from 2 to 3m (6m for late harvested crops introduce in 2022)
Silage bales stored 2 high & 20m from a watercourse
Targeted local authority inspections (4,500)

2-year derogation review – changes in 2024

Dairy farms require 31 days soiled water storage and not allowed spread during all of December
LESS is required on farms with a GSR >130
More Stringent Requirements for out-wintering concession on manure storage capacity
- Grassland stocking rate must be under 130 kg N/ ha. (previously it was 140)

Derogation

New 220kg N/ha derogation limit based on EC criteria

Changes in 2025

To avail of out-wintering manure storage concession, GSR must be less than 100kg N/ha.
LESS is required on farms with GSR >100kg N/ha
Further 5% cut in chemical N for GSR >170 and new N limit for farms <85kg N/ha
New N allowance for cut-only grassland
New N excretion rates for cattle < 90 days old & 1- 2-year-old cattle (male and female)
Reduced N excretion rates for cows on farms with lower CP in concentrates fed all year
Clover required for reseeds on all farms
Max 14% CP in concentrates fed at grass for all farms (previously 15% for SR > 130)
Two-step verification process for transferring organic fertilisers between holdings
- Exporter: 4 days and Importer: 14 July or 14 January
National fertiliser database introduced – reduced requirement for on-farm records
Soil sample location must be specified – Geo-reference or LPIS number

Derogation

SR limit of 170 if out-block > 30 km away
EPA data used for new 220kg N/ha areas

Changes following the introduction of the 6th NAP – 2026

Uninhibited Urea applied in a solid form is no longer permitted
Milking platform must be identified on BISS
New “Milking Platform” nutrient management requirement: When the milking platform SR > 259 kg N/ha, movement of specific quantities of organic nitrogen (20 to 41+ kg/ha) outside of the milking platform based on chemical nitrogen allowance
Nutrient availability of organic P is now 100% (up from 50%) for soils with >20% O.M. at P Index 1 or 2
Soiled water storage on dairy farms is now calculated based on the volume produced per cow during peak periods in October, November, December, or January
Liming application deadlines set: The greater between 5 ton or the full lime requirement to be spread within 2 years of soil analysis date
No changes to the 16, 18, 20 or 22 week organic manure storage periods in the 6^th NAP

Derogation

A nutrient balance calculation is required
Further training requirement

Changes following the introduction of the 6th NAP – 2028

Increase in the storage volumes for dairy cows: Slurry: 0.4m³/week (previously 0.33) and Soiled water: 0.3m³/week (previously 0.21)
Soiled water storage now 15 days on all farms (previously 10 or 15 days depending on year of tank construction, pre or post 2015)
Post-harvest application of sewage sludge to arable land is prohibited in the Barrow Catchment and the Slaney & Wexford Harbour Catchment
A 5% chemical N cut for farms with GSR > 170 in Barrow, Slaney, Nore and Blackwater catchments

Derogation

4m chemical fertiliser buffer in Barrow, Slaney, Nore and Blackwater catchments
8m organic fertiliser buffer in Barrow, Slaney, Nore and Blackwater catchments
20m organic fertiliser buffer in Barrow, Slaney, Nore and Blackwater catchments on land with a 20% slop towards water

This timeline is provided for general informational purposes only and does not constitute legal or professional advice on current regulatory requirements.

For more information on the Agricultural Catchments Programme, visit here.