The regulatory framework is characterised by fear, lack of transparency, and fragmentation, according to Brian Pack speaking at the NFUS annual meeting.
The fear is all to do with the threat of financial penalty.
It is a real enough threat with 5.6 billion euros of disallowances, or fines, applied across 27 member states over the last six years.
This may only be 1.26% of the total CAP budget but it is still a mighty sum.
Over the same period Scottish Government has faced disallowances of 56.4 million euros
Mr Pack said: “It is slightly ironic that the money is used to shore up the EU budget but no farmer wants to be a contributor.
“Inspections can be frightening and it is important that farmers should understand the audit process and they should know why they have been selected for an inspection.
“It could be at random or to check national application of EU rules and not much to do with the individual.”
This is only one of the recommendations made in Mr Pack’s Better Regulation report which is now out for consultation.
“I have called for a shift in mindset for our administrators so they can build in as much flexibility as possible in the enabling legislation,” he said.
The Scottish Government’s chief agricultural officer, Drew Sloan, told the meeting long-term plans for better regulation are being formulated.
“If people understand the complexities they are less likely to face disallowances,” he said.
The SG target is for 77% of queries to be able to be dealt with by one telephone call, although there was some way to go to meet this, Mr Sloan said.
He also conceded that written guidance was often difficult to understand.
A journalist had been employed to make sure that the regulations and requirements were written in plain English.
There was also to be a greater effort to improve explanatory video content.
There were, for example, 200 people working on constructing a new IT system.