The paper discusses the COM proposals for the new delivery model of the CAP post 2020 against the background of evaluation results of German Rural Development Programmes (pillar 2) from several funding periods. Empirical findings from quantitative and qualitative implementation cost analyses show an urgent need for fundamental amendments in terms of a significant reduction of administrative input. This requires an appropriate and proportionate implementation framework. Some approaches in the new delivery model, such as strengthening subsidiarity, address the problems identified. Other elements seems to be essentially geared to the needs of pillar 1 (direct payments). Results orientation and the future CAP strategy plan primarily serve to legitimise direct payments under severe justification pressure. Whether the implementation efficiency of the RDP will increase (without reducing their effectiveness) is open to question.