EU Digital Record Keeping for Farms

If you farm in an EU member state, digital spray record-keeping is no longer optional from 1 January 2027. The obligation comes from Article 67 of Regulation (EC) No 1107/2009, existing EU law that has been in force for years, with the electronic records requirement now confirmed as enforceable from that date.

This article explains what the rules actually require, what IPM obligations mean in practice, and how to make the most of the time remaining before the deadline.

What is now legally required from 1 January 2027

Under Article 67 of Regulation (EC) No 1107/2009, every professional user of plant protection products in the EU must keep electronic records of their applications from 1 January 2027. This is not a proposal, it is existing regulation with a confirmed enforcement date.

What each spray record must include

Additional requirements

• Records must be in electronic format, or converted to electronic format within 30 days of the application
• Records must be kept up to date, quarterly submissions are not sufficient
• Records must be accessible to the relevant national authority on request
• Records must link to a specific geospatial location, "field 3" is not enough; the field must be mapped

What about the SUR?

You may have heard that the proposed Sustainable Use Regulation (SUR) was withdrawn by the European Commission in February 2024 following widespread farmer protests across Europe. This is true. However, the SUR withdrawal did not remove the 2027 digital records obligation, that requirement sits in Article 67 of Regulation (EC) 1107/2009, which predates the SUR and remains fully in force. The deadline is confirmed.

IPM is a legal obligation, not just good practice

Integrated Pest Management (IPM) is legally required for all professional pesticide users in the EU under Directive 2009/128/EC. IPM means farms must consider all available pest control methods, cultural, biological, mechanical, and use chemical pesticides only as a last resort, when other methods are insufficient.

In practice, IPM means:

• Documenting how you monitor pest populations (scouting, traps, observations)
• Documenting the basis for each spray decision (threshold exceeded, alternative methods considered)
• Keeping records that demonstrate chemical applications were made because they were necessary, not as a calendar-based default

Each EU member state monitors IPM compliance at different levels of stringency. Some countries require formal documented IPM plans; others operate through inspection and advisory systems. What is consistent across all member states is that professional pesticide users must be able to demonstrate they are applying IPM principles, and from 2027, that demonstration must exist in digital records.

CAP: what's changing for direct payments

The Common Agricultural Policy (CAP) 2023, 2027 links a portion of direct payments to environmental conditions. Key changes already in force:

• 25% of direct payments are reserved for eco-schemes, environment-friendly practices including precision farming, carbon farming, organic farming, and animal welfare improvements
• CAP climate tracking is being phased in, expect requirements around water usage, electricity consumption, and emissions to develop during the current CAP period
• Employment conditions must be documented in writing for all farm workers, regardless of hours worked, covering place of work, employment terms, remuneration, schedule, and social security information
• On-farm health and safety obligations for machinery, protective equipment, and dangerous substances

How to make the most of the time before 2027

The most common mistake is waiting until 2026 to start. Change on a farm takes at minimum two seasons: one to pilot, one to embed. With the 2027 deadline, that means starting now.

Start with field maps

Every record from 2027 must link to a specific geospatial field location. If your fields are not mapped digitally, this is the first task.

Log spray jobs digitally from this season

The 2027 obligation requires records to be kept in or converted to electronic format within 30 days. Starting now means the habit is established and the data history exists before it becomes compulsory.

Include your agronomist or cooperative

The records authorities will want to see include not just what was applied but the basis for the decision. If your agronomist advises on spray programs, they should be part of the digital record-keeping workflow, not sending recommendations by phone or SMS that then have to be reconstructed.

Test, don't transform

You don't need to change everything at once. Start with one crop, one field, or one team. Once you are confident in the system, scale it to the rest of the operation.

Farmable is already compliant with the 2027 requirements. Every spray job logged in Farmable captures product, date, dose, operator, weather conditions, and field location with a geospatial reference. Records export directly for government reporting systems in Spain (SIEX) and Norway (Mattilsynet), with GlobalG.A.P.-compliant exports available for all markets.

Common questions

This article is general guidance, not legal advice. For the authoritative text, see Regulation (EC) No 1107/2009 Article 67 and Directive 2009/128/EC, and confirm national implementing rules with your member state's competent authority.