EU agriculture commissioner Mariann Fischer Boel revealed the blueprint for her "health check" to the EU parliament's agriculture committee in Brussels last week.
It aims to update previous reforms through a series of interim adjustments to CAP to prepare the way for radical reform in 2013.
But despite welcoming the proposals as going in the right direction, NFU president Peter Kendall said they did not do enough.
He said: "The great failure of the 2003 reform was to allow some governments to retain some partially decoupled support. Although the Commission has proposed to severely curtail partial decoupling in future, this does not go far enough, and we will now urge its total abolition."
He said the suggestion to scale back larger single farm payments was "misguided", adding: "It would introduce more complexity instead of simplicity, especially as farmers would be bound to try to adjust their businesses in order to avoid its impact. The Commission itself does not seem convinced this is the right way forward."
Fischer Boel has stressed the health check is not a reform but fine-tuning.
However, the NFU has welcomed plans such as simplifying and reducing the burdens of cross-compliance, the total abolition of set-aside and preserving the environmental benefits it brought, and offering countries the opportunity to revise their single payment scheme model before 2013 towards an area-based system.