Aim of study: The paper explores whether the legislative proposal for the EU Common Agricultural Policy (CAP) after 2021 and the novelty of comprehensive strategic planning at Member State (MS) level can bring about a greener, more multifunctional policy paradigm. While existing research has explored long-term policy change over the entire decision-making process, this study aims to demonstrate the usefulness of conducting policy analysis at the inception of the legislative procedure.Area of study: The study applies to the European Union.Material and methods: The research employs a qualitative method of policy analysis, using a combination of three theoretical frameworks – social learning, path dependency and intergovernmentalism. Extensive document analysis and in-depth interviews were applied to evaluate the proposed reform and gauge the responses of key interest groups.Main results: The proposal holds potential for a substantial overall greening of the policy but will be strongly dependent on implementation at the MS level; the institutional framework provides space for increased environmental ambition, but does not guarantee it, as the proposed safeguards are too weak.Research highlights: More accountability is required during the formulation and implementation of Strategic Plans. Due to strong elements of path dependency and intergovernmentalism, an overall paradigm shift at EU level is unlikely. Strengthening the role of MSs is weakening the commonality of the policy that guarantees at least minimal environmental standards.