MEDDELELSE FRA KOMMISSIONEN TIL EUROPA-PARLAMENTET, RÅDET, DET EUROPÆISKE ØKONOMISKE OG SOCIALE UDVALG OG REGIONSUDVALGET Status for gennemførelsen af pagten om migration og asyl

EN EN
EUROPEAN
COMMISSION
Brussels, 11.6.2025
COM(2025) 319 final
COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL
COMMITTEE AND THE COMMITTEE OF THE REGIONS
State of play on the implementation of the Pact on Migration and Asylum
{SWD(2025) 162 final}
Offentligt
KOM (2025) 0319 - Meddelelse
Europaudvalget 2025
EN EN
1. INTRODUCTION
The adoption of the Pact on Migration and Asylum (the Pact) in June 2024 marked an
important milestone in the development of the Common European Asylum System (CEAS).
The Pact reforms and further develops the current rules, on the basis of a comprehensive
approach that strengthens and integrates EU policies on migration, asylum, border
management and integration (1
). The Pact creates a legal framework that balances solidarity
and responsibility between Member States, in a comprehensive approach to managing
migration effectively and fairly. The legislative acts of the Pact entered into force on 11 June
2024 and will apply from mid-2026.
The implementation of the Pact is a complex process that involves multiple actors. Work is
well underway to translate the large and complex set of legislative acts into operational
reality. Getting the EU and national systems ready by June 2026 is a joint endeavour that
requires the Member States, the Commission and EU agencies to work closely together.
In June 2024, the Commission adopted the Common Implementation Plan for the Pact on
Migration and Asylum (2
), setting out the key tasks and milestones for this transition period.
Since then, the Commission has steered the implementation of the Pact at EU level and has
continuously supported Member States in their national efforts, together with EU agencies.
The Commission is making available EUR 3 billion in additional funding to support Member
States’ efforts to implement the Pact and in hosting displaced persons from Ukraine. The
Commission is currently working with Member States to finalise the necessary procedures by
the end of the year to fund the objectives outlined in their national implementation plans.
Half-way through the transition period, considerable progress has been made at both national
and EU level. Further efforts are however needed to ensure the full and timely application of
the new rules. Some of these challenges are linked to current deficiencies. Other challenges
are linked to preparing the ground for the application of the new rules introduced by the Pact,
notably the operationalisation of the upgraded Eurodac, the implementation of screening and
the mandatory border procedure, as well as the new fundamental rights safeguards.
Remaining challenges will need to be addressed in time for a full implementation of the Pact.
The Commission calls on Member States to continue and intensify their efforts where needed
to ensure that the implementation of the Pact will be a success. While progress is being made
at technical level, sustained political engagement and ownership at national level remain
essential to address the identified challenges effectively. It is necessary to make as much
progress as possible in implementing the Pact ahead of the start of the annual solidarity cycle.
In particular, it is key that there are no major deficiencies in applying the current rules
because this may have an impact on the overall assessment of pressure and access to the
Solidarity Pool. The Commission, together with the EU agencies, will continue working with
and supporting Member States, including through funding, with a strong focus on action to
overcome the challenges identified.
To adapt and respond to the dynamic nature of migration, the Pact also needs to be
complemented by additional efforts in areas that are not covered by the new legislative
framework. Enhancing global cooperation on migration is particularly important for a
(1
) Communication from the Commission to the European Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions Common Implementation Plan for the Pact on Migration and Asylum,
COM (2024) 251 final, (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52024DC0251).
EN EN
successful and sustainable implementation of the Pact. The EU has invested in comprehensive
partnerships with third countries, which have contributed to decreasing irregular arrivals to
the EU. Based on Frontex data, in 2024 the number of irregular arrivals recorded at the EU
external border was 240 000, a decrease of 37% compared to 2023 (3
). The Union must
continue building and expanding such partnerships with third countries in a mutually
beneficial way to reduce irregular arrivals, scaling up the Global Alliance to Counter Migrant
Smuggling, to reinforce cooperation on return and readmission, to promote talent mobility
through Talent Partnerships, and to provide protection to refugees displaced in non-EU
countries, including through resettlement and humanitarian admission. The Team Europe (4
)
approach has proved to be a successful method when negotiating with relevant third countries
to establish new or to recalibrate existing partnerships.
With this Communication, the Commission informs the European Parliament and the Council
on the implementation of the Pact, in accordance with Article 84 of the Asylum and Migration
Management Regulation (5
). Building on the key actions of the Common Implementation Plan
of June 2024 and in anticipation of the launch of the first annual solidarity cycle in October
2025, this Communication presents a state of play of the progress made at EU and national
level on the implementation of the Pact and provides an overview of the state of
implementation in relation to each of the ten building blocks. As a next step, the Annual
Report on Migration and Asylum of October 2025 will include an updated state of play of the
implementation of the Pact. The Commission will then present a long-term European Asylum
and Migration Management Strategy by the end of this year to support an integrated and
coordinated approach to the implementation of the Pact, both at EU and national level.
Figure 1: Timeline of the transition period
(3
) Frontex Monitoring and Risk Analysis: https://www.frontex.europa.eu/what-we-do/monitoring-and-risk-
analysis/migratory-map/.
(4
) Team Europe Initiatives: https://international-partnerships.ec.europa.eu/policies/team-europe-initiatives_en.
(5
) Regulation (EU) 2024/1351 of the European Parliament and of the Council of 14 May 2024 on asylum and migration
management, amending Regulations (EU) 2021/1147 and (EU) 2021/1060 and repealing Regulation (EU) No 604/2013,
COM (2020) 758 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1351.
EN EN
2. DELIVERING AT EU LEVEL
In line with the Common Implementation Plan, the Commission and the EU agencies, in
coordination with Member States, have worked on ensuring that legal milestones are met and
that the operational planning for implementation is continuously coordinated, updated where
relevant, and translated into operational practice. In parallel, direct bilateral assistance to
Member States has resulted in tailor-made support by the Commission and EU agencies to all
Member States.
At EU level, the Commission also continues working to complete and complement the
legislative framework of the Pact. In March 2025, the Commission put forward a new
legislative proposal for a regulation establishing a common European system for return (6).
Where appropriate, the Commission has also delivered early and proposed to frontload some
of the new provisions of the Pact. It has proposed a European Union list of safe countries of
origin (7), as well as a revision of the rules on the application of the “safe third country”
concept (8), fulfilling the requirement under the Pact to review the application of the concept
by June 2025. Lastly, the Commission has proposed to anticipate two key elements of the
Asylum Procedure Regulation with the aim of supporting Member States to process asylum
claims faster and more efficiently for applicants whose claims are likely to be unfounded.
This includes the Pact provisions related to applicants coming from third countries with low
recognition rates and the possibility to designate safe countries of origin and safe third
countries with exceptions.
2.1 Steering, guidance and dialogue
The tasks and milestones outlined in the Common Implementation Plan for delivery at EU
level by June 2025 have been fulfilled. The Commission has established a Pact
Implementation Platform to provide steer, which met for the first time in January 2025 to
discuss national-level planning and the strategic programming of dedicated EU financial
support. The Strategic Committee on Immigration, Frontiers and Asylum (SCIFA) also
provides steer through regular discussions on the implementation of the Pact.
Exchange with the European Parliament is recurrent in the framework of the Working
Group on Asylum - Implementation of the Pact/Common European Asylum System of the
Committee on Civil Liberties, Justice and Home Affairs.
The technical work proceeds apace, with the support of contact committees and expert group
meetings to ensure a common interpretation and clarification of legal provisions. This has led
to the timely preparation of required implementing acts (9
) and the sharing of good practices
across all components of the Pact. The agencies’ networks have also helped identifying
common operational challenges and solutions, including through the development of
templates and guidance documents. To avoid duplication, and promote simplification, and to
ensure synergies, the Commission also organised various joint sessions of committees and
(6
) Proposal for a regulation of the European Parliament and of the Council establishing a common system for the return of
third-country nationals staying illegally in the Union, and repealing Directive 2008/115/EC of the European Parliament
and the Council, Council Directive 2001/40/EC and Council Decision 2004/191/EC, COM(2025) 101 final EUR-Lex -
52025PC0101 - EN - EUR-Lex.
(7
) Proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1348 as
regards the establishment of a list of safe countries of origin at Union level COM(2025) 186 final EUR-Lex -
52025PC0186 - EN - EUR-Lex.
(8
) Proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1348 as
regards the application of the ‘safe third country’ concept, COM(2025) 259 final EUR-Lex - 52025PC0259 - EN - EUR-
Lex.
(9
) The different implementing acts for the Pact legislative acts are listed in Annex to the Common Implementation Plan:
EUR-Lex - 52024DC0251 - EN - EUR-Lex.
EN EN
expert groups, covering different Pact elements back-to-back with the agencies’ network
meetings.
Direct bilateral support of the Commission to Member States continues to be a strong focus of
the common work across all elements of the Common Implementation Plan. This approach
provides fit-for-purpose support, adapted to national circumstances and the different
institutional arrangements of each Member State. The Commission set up dedicated country
teams and liaison at senior officials’ level to interact with each Member State.
The Commission services’ country teams have engaged bilaterally with Member States’
authorities and provided an underlying analysis of Member States’ systems and related
challenges, which fed into the national implementation plans (NIPs). Work is now focusing
on the implementation and operationalisation of the NIPs. Member States are working with
the Commission’s support to ensure that sufficient funding under EU Funds and national
budgets is allocated to the objectives under each Plan.
Furthermore, through a dedicated call in 2024, nine Member States made use of the support
provided through the Technical Support Instrument (TSI) for the preparation of their NIPs (9
).
Currently, the Commission supports ten Member States through the TSI on the
implementation of the Pact. In addition, Member States are benefiting from peer learning and
good practice exchanges set up in the context of the TSI. To promote a multi-stakeholder
approach, the Commission held dedicated information and consultation meetings with
stakeholders, such as social and economic partners, international and civil society
organisations, in particular migrant-led organisations10
.
2.2 The work of the EU agencies
The work of the EU agencies to implement the Pact, notably the European Union Asylum
Agency (EUAA), the European Border and Coast Guard Agency (Frontex) and eu-LISA, is
advancing.
The EUAA has been facilitating Member States’ transition to the new legal framework
stemming from the Pact and supported the Commission in the development of the Common
Implementation Plan. Within the framework of its national expert networks, the EUAA has
updated its products and guidance and developed new ones where required by the Pact or
where needed. The EUAA is currently updating the European Asylum Curriculum training
modules and is reviewing the relevant operational standards and indicators (further details are
provided in section 3 under each building block).
Additionally, two pilot monitoring exercises (in Estonia and the Netherlands) will take place
in 2025 to prepare for the full roll-out of the EUAA multiannual monitoring programme from
2026 onwards. Under the programme, all Member States will be monitored in terms of their
technical and operational implementation of the Pact in a 5-year cycle. The outcomes of the
monitoring will also support the Commission’s assessment of whether national asylum and
reception systems are well prepared.
Frontex continues to provide support across those areas that fall under its mandate, providing
practical guidance and tools, as well as operational support on demand, in particular in
relation to the planning and implementation of new processes at the border. The various
elements related to the implementation of the Pact are discussed in the Frontex working
groups and networks, as well as in dedicated ad hoc meetings with Member States.
Furthermore, Frontex provides support to Member States in all phases of the return process, in
close cooperation with the EU Return Coordinator. Frontex also cooperates with the Member
(10
) European Commission and NGOs discuss the implementation of the Migration Pact: https://home
affairs.ec.europa.eu/news/european-commission-and-ngos-discuss-implementation-migration-pact-2024-05-27_en.
EN EN
States on the development of risk assessments and plays a role in quality control of the
borders. Frontex’s annual vulnerability assessment, which evaluates the capacity and
readiness of each EU Member State and Schengen Associated Countries to respond to
challenges at its external borders, will facilitate the transition to the new legal framework.
eu-LISA plays a crucial role in the implementation of the Pact, particularly to further enhance
the effective management of the Union’s external borders, the establishment of uniform rules
ensuring control, and the proper registration of irregular migrants and asylum seekers entering
the EU. The good functioning of the new Pact rules depends on the effective availability and
functioning of the new Eurodac by 12 June 2026. eu-LISA is continuously supporting
Member States in this challenging task (further details are provided in section 3.1).
To ensure synergies between the work of the Commission and of the EU agencies, the former
should develop the horizontal legal guidance, while the latter should primarily focus on
developing targeted operational guidance and support. The Commission and the agencies will
continue working together to achieve high-level efficiency and decrease the burden placed on
the Member States, in line with the overall Commission’s objective of simplification.
2.3 Financial support
The EU is making an additional EUR 3 billion available to Member States to support the
implementation of the Pact and hosting displaced persons from Ukraine. This represents a
further increase of EUR 1 billion compared to the amounts announced in the Common
Implementation Plan. In addition, qualifying Member States can also make use of the more
than EUR 1.6 billion available under the mid-term review of the Home Affairs Funds11
.
Member States should use these additional funds strategically to advance on their
implementation efforts as much as possible, while giving priority to addressing the most
important challenges identified in their National Implementation Plan and in dialogue with the
Commission. The Commission has supported the Member States in identifying their
priorities, and the programming of this additional funding should match Member States’
National Implementation Plans. While the additional amounts are significant, the scale of
reforms of the Pact will require Member States to identify other relevant funding sources at
national and EU level (e.g. cohesion policy) to cater for all their needs. It is critical to ensure
that the required amendments of Member States’ programmes are finalised at the latest by the
end of the year and that public procurement procedures are launched and completed on time.
Most Member States are on track to reach this target, with further efforts needed in some
Member States (12
), and are identifying other relevant funding sources at national level, as
well as other funds at EU level, such as those under cohesion policy, while seeking more
synergies and complementarities.
3. NATIONAL IMPLEMENTATION PLANS AND OPERATIONALISATION OF THE BUILDING
BLOCKS
3.1 Overview of National Implementation Plans and coordination
The Common Implementation Plan set the common objective of having well-prepared
systems in place by the end of the transition period. To ensure that systems are well prepared,
Member States need to implement the new rules of the Pact and address existing challenges in
relation to their national laws, practices and operational capacity.
(11
) Asylum, Migration and Integration Fund (AMIF) and Integrated Border Management Fund (BMVI).
(12
) As of 6 June, there are concerning delays, if for different reasons, in: Belgium, Greece, Latvia, Malta, Poland, Spain.
EN EN
All Member States were required to establish national implementation plans (NIPs) with clear
actions and timelines, including on procurement, training, and recruitment needs. To date, 26
Member States have regularly engaged with the Commission on the implementation of the
Pact, and 25 Member States submitted their national implementation plans (13
). The four
Schengen Associated Countries also submitted their NIPs, covering elements of the Pact in
which they take part.
All NIPs are based on the template that the Commission provided and thus reflect the building
block structure of the Common Implementation Plan. About one third of the plans were also
released as public documents (14
).
The Commission supported Member States in the assessment of their current systems to help
establish baselines for planning, and provided some recommendations, which are reflected
across a large majority of NIPs. In general terms, the level of detail of the NIPs varies across
Member States and, within the NIP of a given Member State, by policy area or building block.
Depending on the case, this can reflect the fact that either the assessments and reviews were
still ongoing at the moment of submission, or that less work was needed in some areas or
building blocks. Most Member States still need to define concrete milestones and targets to
track and monitor implementation, which is useful in detecting and remedying critical delays.
The implementation of the Pact is not a one-off process but a dynamic one. Since the initial
submission of the NIPs, some Member States have updated and reviewed elements of their
NIPs (15
), reflecting the considerable work that is underway. Legislative elements are
addressed in all NIPs, albeit to different degrees of detail. The work on the necessary
legislative changes has started across Member States. At least three Member States have
already finalised the drafting of the relevant national legislation and are preparing for
adoption (16
). A good number of other Member States are expecting to finalise the process
still this year. However, there is a need to accelerate this process in some others.
Member States have established planning and coordination mechanisms to deliver at the
operational level and should now use them to implement the Pact effectively. Preparing the
NIPs has helped identify national coordination issues. While many Member States are
strengthening integrated policymaking through inter-ministerial arrangements, others need
stronger coordination across policy areas and levels of government. Though migration or
interior ministries will lead, involvement from other ministries, the judiciary, and local
authorities is essential. The Commission welcomes and continues to call for good
coordination with all stakeholders, and the involvement of local and regional authorities, as
well as civil society, to achieve a high level of efficiency when implementing the Pact. To that
end, building on the streamlined system put in place by the Pact (e.g. transfer procedures,
closer links between asylum and return, better use of databases), the Commission will
continue exploring ways to further streamline the related work and decrease the overall
administrative burden in line with the Commission’s objectives on simplification. The
upcoming long-term European Asylum and Migration Management Strategy will be an
opportunity to further address integrated and streamlined policymaking.
The Commission remains in close dialogue with and supports all Member States on planning
and operational aspects. The Commission is also in close touch with the Member States that
(13
) Hungary communicated to the Commission that it does not intend to prepare a NIP. Poland submitted its position on the
implementation of the Pact. Ireland also submitted a NIP because it notified its participation in the EU Pact on Migration
and Asylum
(14
) Austria; Bulgaria; Czechia; Germany; Lithuania; Luxemburg; the Netherlands; Slovakia; Slovenia; Sweden (on
demand).
(15)
For example, Greece, Spain and Belgium.
(16
) Czechia, Estonia, the Netherlands.
EN EN
did not submit a NIP and urges all Member States to complete this process as soon as
possible.
3.2 Building Block 1 - Eurodac
The swift development and entry into operation of the reformed Eurodac system is a critical
precondition to properly implement all elements of the Pact. The reform of Eurodac is a
shared responsibility between the Commission, eu-LISA and Member States, and significant
progress has been made so far. The preparation of non-legislative instruments required for its
implementation is on track as is eu-LISA’s development of the new Eurodac, building in part
on the Interoperability Framework components that Eurodac will use.
Given the challenging timeline for Eurodac’s implementation, the Commission, eu-LISA and
Member States have identified a set of measures to mitigate delays. These were mainly put
into place by eu-LISA to support Member States. One such measure is that Eurodac
functionalities are to be delivered in two phases (June and December 2026), prioritising the
functionalities identified as critical for June 2026. Another measure is that eu-LISA developed
a centralised solution, a Web-User Interface (WUI). The centralised solution should be used
by Member States who, for various reasons such as a lack of resources, are not ready to
achieve a full system-to-system integration by June 2026.
Moreover, eu-LISA opted to take a flexible approach for implementing the Eurodac system,
allowing the Agency to share the various necessary technical documents in stages. This meant
that key documentation could be shared early with the Member States facilitating the
collection and use of the shared expertise existing in all Member States. This way, the first
Interface Control Document (ICD) was delivered in October 2024, followed by the full ICD
delivery in December 2024, as required by the Regulation. The same flexible approach was
also adopted for the testing. The voluntary basic connectivity testing between Member States
and eu-LISA has already started, with several Member States already successfully completing
it.
At national level, when building their system, Member States may choose between using the
centralised solution provided by eu-LISA, or building a national system that fully integrates
Eurodac, or a combination of the two (i.e. first the centralised solution and then a system-to-
system integration). Thanks to the above-mentioned flexible approach adopted by eu-LISA,
Member States were able to start the development of the system at national level relatively
early. Regular meetings organised by eu-LISA (Project Management Forum, Advisory
Group) allow Member States to report periodically on the state of play of the national-level
implementation and to flag any challenges that could have repercussions for the entire project
at EU level. Until now, these exchanges have indicated that, despite good progress, some
Member States face challenges. These include deciding which national authority is
responsible for the implementation of the system or which authority hosts the national access
point, difficulties in procurement procedures, scarce resources (human or financial), or
continuous requests for the technical documentation (17
).
On its side, the Commission participates in all the meetings organised by eu-LISA where
Member States report on the state of play of the implementation and the latest developments
and potential challenges are monitored and discussed. In March 2025, the Commission sent a
letter to all Member States underlining the progress reached until then and reiterating the
importance of the timely implementation of Eurodac, both at the central and Member States’
level. The Commission also organised bilateral meetings with those Member States facing
(17
) During the meeting of the Advisory Group on 15-16 May the following Member States reported themselves at risk or
were considered as such due to lack of reporting: Denmark, Finland, Germany, Cyprus, Greece.
EN EN
particular challenges. The preparation of the acts necessary for the functioning of the system
(on the content of the cross-system statistics and on interoperability) is ongoing.
Key challenges and next steps
eu-LISA should continue to work closely with the Member States and the Commission. The
core ICD elements should at present be considered stable enough to allow Member States to
launch procurement procedures where necessary. No other major changes should be included
at this stage; any further changes in the document should only include minor adjustments
stemming from Interoperability-related ICDs, typos or tweaks following testing. Stabilising
the ICD now will however not prevent that over time further improvements are made to the
system. Those Member States that would prefer a full system-to-system integration should
not completely exclude the possibility of relying on the eu-LISA developed central solution as
a backup, if there are delays in the integration process.
Over the next months, regular monthly reporting will be important to assess the overall status
of implementation and allow the Commission and eu-LISA to provide additional support
where necessary. Member States should make full use of the Eurodac Project Management
Forum and proactively notify the Commission in case of major difficulties.
On the practical side, procurement processes need to be completed as soon as possible,
training plans and recruitment processes put in place, and the necessary mandatory
operational tests done. It is important that the agreed implementation timeline is respected,
and all attention goes to national development, testing and operational readiness.
3.3 Building Block 2 – A new system to manage migration at the EU external
borders
Preparations for putting in place the new mandatory border procedure are underway. In
August 2024, the Commission adopted the implementing act setting out the adequate capacity
for each Member State and the maximum number of applications for international protection
beyond which Member States will not be obliged to apply the border procedure (‘annual
cap’) (18
).
The Commission is working on a guidance document on screening in order to provide a living
document that addresses screening at the external borders and within the territory, including
important considerations also for Member States concerned by secondary movements.
To help ensure policy coherence, screening was also included in the strategic guidelines of the
multiannual strategic policy cycle for European integrated border management (EIBM) (19
).
Frontex is on track in developing, in cooperation with EUAA and the Commission, its
“screening toolbox”, which includes practical tools for the conduct of the screening-related
checks and verifications. Operational testing of these tools is scheduled to start in September
2025.
The Commission and the EUAA issued a series of tools directly relevant for setting up the
new mandatory border procedure. These include hypothetical adequate capacity models,
including the possibility of having ‘multipurpose centres’ that combine screening and the
asylum and return border procedures. These models include indicative staffing and reception
requirements for screening and the border procedures, to support national planning and the
(18)
Commission Implementing Decision (EU) 2024/2150 of 5 August 2024 laying down rules for the application of
Regulation (EU) 2024/1348 of the European Parliament and of the Council, as regards the adequate capacity of Member
States and the maximum number of applications to be examined by a Member State in the border procedure per year, OJ
L, 2024/2150, 9.8.2024 http://data.europa.eu/eli/dec_impl/2024/2150/oj.
(19
) In November 2024, Frontex updated the Annex of Technical and Operational Strategy for European Integrated Border
Management to include Screening.
EN EN
setting up of targets for delivery. The EUAA has issued a blueprint for multipurpose centres,
which provides for several steps of the process in one location (e.g. screening, registration,
border procedures) to help Member States in the design of these centres. The EUAA,
cooperating with Frontex, also issued the new Guidelines on alternatives for detention10
that
could be used in the context of the border procedure. The Commission is also developing a
guidance document on the asylum and return border procedure.
At national level, some Member States already have the reception facilities and human
resources needed to cater for their adequate capacity in place. Others have concrete plans on
how to do so, including by allocating funds for the required infrastructure and personnel (20
),
and plans for building, renovating or repurposing multi-purpose centres. The exercise to
model the screening carried out by Romania in 2024 was useful to test screening operations
and share experience with other Member States.
Key challenges and next steps
Member States have until April 2026 to notify the locations designated for border procedure.
So far, no Member State has done so. Member States risk facing delays in setting up their
capability and capacity for screening and the mandatory border procedure if the final locations
are not designated soon, and that the financial planning and related procurement processes are
not initiated and concluded (21
). The ongoing programming of additional EU funding can
support Member States in delivering on this important task. The Commission will be in
contact with Member States to advance on these aspects, notably as it is not possible, at the
moment, for the Commission to fully assess the progress made by Member States and the
possible risks they may be facing.
The implementation of the mandatory border procedure will need to be accompanied by an
independent fundamental rights monitoring mechanism (see section 3.10) and rely on
effective cooperation with the judiciary to meet the deadlines and take account of procedural
changes introduced by the Pact. Member States have identified cooperation with the judiciary
as an important element of the implementation process. This requires taking into account the
additional needs of the judiciary, ensuring the independence of the judiciary and meeting the
requirements established by EU law for courts or tribunals.
Member States need to ensure the timely involvement of various stakeholders and the
allocation of sufficient funds for all elements of the adequate capacity. As regards the
phasing-in of the screening, there are some challenges related to designating sufficient
facilities and human, material and technical resources to cope with peaks in migratory flows,
as well as to provide effective mechanisms and legal tools to prevent absconding. Efforts must
also be made to have in place sufficient trained staff and medical professionals to carry out
screening, and the technical infrastructure to consult speedily the relevant EU and national
databases, both at the designated borders and within the territory.
3.4 Building Block 3 - Rethinking reception
Almost all Member States are implementing administrative and organisational reforms in
response to the changes introduced by the Pact.
This process involves changes to their case management systems and IT infrastructure (22
),
also using TSI support, as well as investment in infrastructure, whether in terms of renovating
(20
) Member States who either already reached their adequate capacity requirements or are progressing towards reaching it
on time: Belgium, Finland, Luxembourg, Czechia, France, Malta, The Netherlands, Romania.
(21
) Countries where there are concerns about reaching adequate capacity on time given the length of procurement
procedures include: Italy, Germany. Stronger concerns: Estonia and Greece.
(22
) Austria, Belgium, Estonia, Finland, France, Croatia, Ireland, Luxembourg and Portugal.
EN EN
or establishing new structures. Almost half of all Member States plan for new reception
centres of different types and for different groups of residents (23
). Furthermore, Member
States are reviewing operational workflows and setting up new inter-agency cooperation
arrangements with service providers and partners, for example relating to procurement
procedures, healthcare, the assistance to be provided to unaccompanied minors or the labour
market.
Member States are also exploring ways to strengthen self-reliance of and support to applicants
who voluntarily forgo state-sponsored accommodation solutions (24
). Some Member States
focus on early integration measures, including language classes in line with the new
requirements of the Reception Conditions Directive (25
). Other Member States have identified
actions to strengthen medical and psychosocial support (26
).
Additionally, Member States are in the process of transposing into their national legislation
the Reception Conditions Directive and its new tools to manage reception. Member States’
transposition efforts are supported by the Commission and the EUAA in the framework of the
Commission Expert Group on the Reception Conditions Directive and the EUAA Network of
National Contact Points on Reception. Furthermore, the Commission developed an
explanatory document that was shared with Member States in December 2024 (27
). In parallel,
Member States are developing methods to monitor the presence of applicants and on making
available and applying alternatives to detention (28
).
Key challenges and next steps
The timely transposition of the Reception Conditions Directive continues to require attention
across all Member States. Ensuring sufficient capacity and adequate conditions is a key
element for a Member State to be well prepared.
Challenges persist in a number of Member States (29
) related to a suitable capacity in the
national reception systems. In some cases, this has already been identified by the relevant
courts. It is essential that Member States address the real reception needs of today, as required
by the current acquis, and maintain sufficient capacity in their reception system that ensures
an adequate standard of living, while having their contingency plans well developed and up to
date (more information on contingency in section 3.9).
As the recast Reception Conditions Directive further harmonises the standards to be provided
to applicants, Member States should refrain from decreasing or diverging from these
standards or decreasing the overall capacity of their reception systems. Moreover, Member
States’ systems should enable a clear differentiation between ‘adequate standards of living’
and reduced material reception conditions in certain cases (30
) linked to abuses by applicants,
as provided for in the Reception Conditions Directive. In case of reduced material reception
conditions, Member States should, as a minimum, continue to provide for basic needs, which
need to be defined in national systems also in line with the case law of the Court of Justice of
(23)
Multipurpose centres: Czechia and Croatia; Housing for unaccompanied minors: Cyprus and Italy; Housing for
vulnerable persons: Slovakia; Dublin centres: Belgium; (Multipurpose) centres at the border: Ireland, Portugal and
Slovakia. Others focus on increasing general capacity: Luxembourg and Romania and detention centres: Italy.
(24
) For example, Belgium and Estonia.
(25)
This includes Czechia, Cyprus, Italy and France.
(26
) For example, Czechia, Belgium, Slovenia, Lithuania and Latvia.
(27)
The EUAA will also issue its practical guide on setting up and managing an arrival/reception centre in the coming
months.
(28
) Examples are Czechia, Portugal and Luxembourg.
(29
) This includes Belgium, France, Greece, the Netherlands.
(30
) For example, if the applicant moves without authorisation to another Member State or fails to comply with reporting
duties or misleads the authorities.
EN EN
the EU. Some Member States should also review their detention capacity and significantly
improve the general conditions of their detention facilities.
Furthermore, convergence towards adequate standards of reception for international
protection applicants is essential for the Pact to function properly, including to prevent
secondary movements, for transfers under the responsibility rules, and to determine that a
Member State is well prepared.
Remaining gaps related to the collection of the necessary reception data will need to be
addressed swiftly. Moreover, especially related to early integration measures, Member States
should focus on the timely establishment and review of adequate multistakeholder
partnerships.
3.5 Building Block 4 - Fair, efficient and convergent asylum procedures
Member States are focusing on reviewing their national legislation to adjust to the new legal
framework. Some Member States face a significant backlog in asylum cases, due to structural
issues, or limited staffing and infrastructure resulting in long processing times. Most Member
States concerned have taken steps to address existing backlogs and reduce the duration of
procedures, as well as avoid the need to run two parallel systems for too long after June 2026
- one governed by the current acquis and the Asylum Procedures Directive, and one based on
the Asylum Procedure Regulation in relation to applications lodged as from 12 June 2026. A
number of Member States have put plans in place to enhance their capacity by increasing the
number of permanent staff (31
) or by creating dedicated teams to tackle the backlog (32
). Some
Member States have sought targeted additional support for this via the TSI or the EUAA (33
).
Discussions held in expert committees serve to clarify legal provisions of the new legislation
and help with the transition between the two systems.
Digitalisation, especially the use of integrated case management systems, and automated
notifications for the efficient and secure transmission of information, is an important element
for those Member States that are reviewing and streamlining their workflows and standard
operating procedures, especially when different authorities are involved. Bulgaria for example
is using TSI support to move forward on the digitalisation of asylum procedures.
Key challenges and next steps
The existing challenges regarding access to the asylum procedure, including delays in
registration and appointments for lodging applications, need to be addressed. In building up
their capacity, Member States should ensure that the necessary recruitments are done on time
and adequate training is provided.
As part of their programming exercise, Member States should actively liaise with the
judiciary to verify and, where necessary, expand capacity for processing appeals. This is
needed to reduce the processing time of applications for international protection and ensure
the overall efficiency of the system, reducing the existing backlogs and avoiding the
emergence of new ones. Similarly to the situation of administrative authorities, it is of crucial
importance to ensure, where needed, a timely and adequate training of judges.
Member States need to ensure that pushback allegations are investigated swiftly to guarantee
the respect of fundamental rights, including the right to access asylum procedures and the
principle of non-refoulement. As indicated in the Commission Communication on countering
(31
) As done in Bulgaria.
(32
) As done in Portugal.
(33
) Belgium and Germany.
EN EN
hybrid threats from the weaponisation of migration (34
), any measures taken to address the
weaponisation of migration affecting the borders with Belarus and Russia and restricting
fundamental rights (e.g. the right to asylum), have to be temporary, proportional and limited
to what is strictly necessary, and ensure that the essence of those rights is respected.
3.6 Building Block 5 - More efficient and fair return procedures
The Commission has worked closely with Member States, in the context of the development
of the National Implementation Plans, to bring asylum and return authorities closer together.
To date, 19 Member States already issue negative asylum decisions and return decisions at the
same time, which will be a requirement under the Pact, aiming at further simplifying and
streamlining administrative processes. Within the framework of the High-Level Network for
Returns, dedicated workshops were organised to share experiences and identify best
practices (35
). Similar workshops were also organised on last-minute asylum applications and
on ways to accelerate the return process, improving coordination and reducing the time
between the rejection of asylum applications and return procedures.
Meanwhile, several Member States are upgrading their national return case management
systems to enable more efficient monitoring of return, establish automated integration with
the broader migration management IT systems, and ensure more complete and effective use of
the Schengen Information System.
As presented in the 2025 State of Schengen report (36
), the thematic Schengen evaluation on
the effectiveness of the return system, carried out in 2024, highlighted both developments on
the ground and persistent internal obstacles hampering returns. Some Member States have
established or strengthened integrated planning for all authorities involved in the return
process, enabling regular coordination and more effective resource allocation. However, there
is still a need for better risk analysis and forward planning for return, which would support
strengthening preparedness and resource allocation, including for defining the necessary
support from Frontex. Two Member States (37
) have reassessed existing return capacities,
including their ability to address the risk of absconding, and are in the process of increasing
those capacities. In some Member States (38
), voluntary return programmes have been
reinforced, which can significantly enhance the overall effectiveness of return.
Frontex actively supports Member States in their efforts to implement the key novelties of the
Pact on return. This includes ongoing technical work to map Member States’ needs to be able
to plan the Agency’s support. Frontex EU Reintegration Programme is playing an
increasingly important role in promoting more voluntary returns from the EU and is now
actively being used by almost all Member States
The Commission’s proposal of 11 March 2025 for a Regulation establishing a common
system for return of third-country nationals staying illegally in the Union constitutes a key
piece to complement the other Pact proposals, with a view to putting in place swifter, simpler
and more effective returns, in full respect of fundamental rights.
(34
) Communication from the Commission to the European Parliament and the council on countering hybrid threats from the
weaponisation of migration and strengthening security at the EUs external borders, COM(2024) 570 final, EUR-Lex -
52024DC0570 - EN - EUR-Lex.
(35
) The Netherlands and Norway.
(36
) Commission reports on the State of Schengen, celebrating 40 years: https://home-affairs.ec.europa.eu/news/commission-
reports-state-schengen-celebrating-40-years-2025-04-23_en.
(37
) Belgium and France.
(38
) Austria, Bulgaria, the Netherlands and Norway.
EN EN
Based on relevant exchanges with Member States, at the end of 2024 the Commission
published a staff working document listing the ways to prioritise and streamline the return of
third country nationals considered as a threat to public security (39
).
In the context of the annual assessment of third countries’ cooperation on readmission under
Article 25a of the Visa Code, the Commission is paying particular attention to the relevance
of readmission cooperation of third countries whose nationals are likely to be subject to the
border procedure.
Key challenges and next steps
The Commission considers it a priority to advance in the negotiations on the abovementioned
proposal for a Regulation on return and calls on the European Parliament and the Council to
conclude the negotiations as soon as possible, and in any event before the Pact starts applying
in June 2026.
Member States will need to address existing internal inefficiencies, such as limited
coordination between authorities and overly complex procedures, to ensure the most effective
implementation of the new obligations under the Pact, particularly those related to the return
border procedure. The overall effectiveness of the return system depends on adequate
resources, seamless processes for continuous follow-up on the return of third-country
nationals, and treating return as a planned and predictable process (40
).
The EU Return Coordinator continues to support Member States to address these challenges.
The Return Coordinator is developing a manual on efficient workflows to guide actors
involved in the return border procedure in Member States and continues to encourage the use
of the return alert in the Schengen Information System.
A targeted return action on preparedness and contingency planning for returns, launched by
the EU Return Coordinator in March 2025, aims at promoting good practices that some
Member States have already in place and helping identify the key and shared elements of
contingency planning for return, to foster a coherent common approach across the EU.
Frontex will play an important role in the implementation of this targeted return action.
Frontex will share with Member States a comprehensive survey on the needs for possible
Frontex support on return in 2026. The Agency is following up on the introductory meeting
held in November 2024 with dedicated bilateral meetings with all interested Member States to
better plan and explore how the individual needs of the Member States can be addressed.
3.7 Building Block 6 - Making responsibility work
The good functioning of the existing Dublin rules and of the new rules, as provided for by the
Asylum and Migration Management Regulation (AMMR), on the fair sharing of
responsibility is of fundamental importance for the overall functioning of the Pact.
In recent years, the rate of Dublin transfers across the Union has been very low, significantly
hampering the effectiveness of the system. The technical work by the Commission and at
national level is focused on making transfers work.
(39
) Commission Staff Working Document on the return of illegally staying third-country nationals posing a security
threat, 17.12.2024: https://home-affairs.ec.europa.eu/document/1a5b1f9c-af3b-4dc7-a01f-
55d64c43b926_en.
(40
) Communication from the Commission to the European parliament, the European Council, the Council, the European
Economic and Social Committee and the Committee of the Regions 2025 State of Schengen report, , COM(2025) 185
final EUR-Lex - 52025DC0185 - EN - EUR-Lex.
EN EN
The Commission is finalising the implementing act that will repeal the current implementing
rules with a view to adoption in July 2025 (41
). In operational terms, this will facilitate the
cooperation and exchange of information among Member States, and thus make transfers
quicker and easier. In addition, this will include standard forms for take-charge requests and
take-back notifications, for transfers, as well as for the relocation procedure and exchanging
information. The new implementing rules have been drafted in close cooperation with the
Member States. Once they are adopted, eu-LISA will implement technical adaptations for the
introduction of these procedures in each Member State’s system.
During a dialogue with Member States on the assessment of their needs for the Pact’s
implementation, the Commission paid particular attention to the need to improve the system
of responsibility and the functioning of national Dublin units. The Commission’s
recommendations to Member States focused on having a well-functioning responsibility
system and ensuring the effective implementation of transfers among Member States. Most
Member States have put in place plans to increase staff, review workflows and/or upgrade the
existing infrastructure for effective case management.
In April 2025, the EUAA published two templates for family tracing forms to facilitate
determination of responsibility: one for adult applicants, and another one for unaccompanied
minors (42
). Both forms are accompanied by a Practical Guide on family tracing, both in the
EU Member States and Schengen Associated Countries, and in third countries (43
).
Key challenges and next steps
All Member States will need to ensure that they apply the new rules, including on take-charge
requests, take-back notifications and transfers. An increase of the overall number of
implemented transfers will contribute to the effective functioning of the system, reducing
incentives for unauthorised movement and ensuring that the balance between responsibility
and solidarity of the Pact is maintained. Since conditions are in place for transfers to function
to and from all EU Member States, and in view of applicable rules, transfers should take place
towards all Member States already now. This is essential for the effective transition to the
new responsibility rules, and for the proper functioning of the annual solidarity cycle.
Moreover, the implementation of the new responsibility rules is closely linked to the effective
implementation of the new Eurodac Regulation. In addition to the technical readiness,
Member States must ensure that their national authorities have access to all information
relevant to the determination of the Member State responsible and are able to access the
system to update the data with relevant information, such as indicating the Member State
responsible, in accordance with both the AMMR and the Eurodac Regulation.
Once the new implementing rules are adopted, eu-LISA will take technical measures to make
it easier and faster for Member States to communicate via DubliNet.
3.8 Building Block 7 – Making solidarity work
Preparatory work continues to start operationalising the annual solidarity cycle in October
2025, and to establish the permanent solidarity mechanism and the Technical-Level EU
(41
) Commission Implementing Regulation (EU) No 118/2014 of 30 January 2014 amending Regulation (EC) No 1560/2003
laying down detailed rules for the application of Council Regulation (EC) No 343/2003 establishing the criteria and
mechanisms for determining the Member State responsible for examining an asylum application lodged in one of the
Member States by a third-country national , OJ L 39, 8.2.2014, p. 1-43, ELI:
http://data.europa.eu/eli/reg_impl/2014/118/oj.
(42
) Art. 22(1) AMMR.
(43
) Practical Guide on Family Tracing Part 1: https://euaa.europa.eu/publications/practical-guide-family-tracing-part-i-
principles-practices; Practical Guide on Family Tracing Part II: https://euaa.europa.eu/publications/practical-guide-
family-tracing-part-ii-tracing-AMMR.
EN EN
Solidarity Forum by June 2026. The solidarity mechanism of the Pact allows Member States
to choose between relocations, financial contributions, and in-kind support when it comes to
their contributions.
Work so far has centred around the Solidarity Platform ‘Pact’, bringing together Member
States, the Commission and the EUAA. A Solidarity Platform ‘Pact’ meeting took place in
April 2025 to discuss key aspects of operationalising the solidarity mechanism and to advance
preparations for the establishment of the Technical-Level EU Solidarity Forum. The
Commission presented draft terms of reference and rules of procedure for the Technical-Level
EU Solidarity Forum to Member States and announced the appointment of the EU Solidarity
Coordinator (44
). A meeting of the Commission Expert Group on the AMMR was dedicated to
discussing the solidarity mechanism and the various modalities for the provision of different
solidarity measures available (45
). A mechanism has been developed for the financial
contributions, to be set out in the related AMMR implementing act.
The implementation of the solidarity mechanism requires timely exchange of quality data
from the Member States. The Commission is therefore working closely with the EU agencies
and Member States in the framework of the Migration Preparedness and Crisis Blueprint
Network to identify and address the needs and challenges of gathering and/or transmitting
data for the purpose of the annual solidarity cycle. From April to November 2024, the
Commission carried out a test run to gather data and ensure consolidation and analysis-
sharing for the European Annual Asylum and Migration Report. On this basis, an efficient
information-sharing process has been designed. The Commission has also concluded relevant
working arrangements with EUAA and Frontex, and one with Europol is in preparation. A
common evidence base and data sharing are essential for the successful implementation of the
Pact.
Key challenges and next steps
The preparatory work for the first Annual Asylum and Migration Report is ongoing. Member
States and EU agencies submitted the requested information to the Commission by 1 June.
Close cooperation with the EU agencies resulted in significantly simplified and streamlined
processes of data and information gathering. The Commission, the European External Action
Service, Member States and EU agencies will exchange on the first draft Report in a
dedicated meeting of the Migration Preparedness and Crisis Blueprint Network in July, in
view of its adoption by 15 October. It remains crucial that Member States continue reporting
the data and information required in a timely, accurate and complete manner, covering also
return and reception.
The analysis in the Annual Report will underpin the Commission’s implementing decision
identifying Member States under migratory pressure, at risk of migratory pressure or facing a
significant migratory situation. That analysis will also serve to prepare the Commission’s
proposal for a Council implementing act establishing the Annual Solidarity Pool necessary to
address the migratory situation. Both proposals are due latest by 15 October 2025.
The designation by the Commission of Member States under migratory pressure, at risk
thereof or facing a significant migratory situation will include the assessment of whether
national systems are well prepared. Such an assessment will have a direct impact on the
possibility for those Member States to be able to access the Solidarity Pool and/or request a
full or partial deduction of their solidarity pledge.
(44
) An EU solidarity coordinator, established by the Asylum and Migration Management Regulation, will coordinate the
implementation of the solidarity mechanism, notably through the Technical-level Solidarity Forum.
(45
) Article 46 (2) AMMR.
EN EN
The assessment of the Commission will also consider the possible existence of systemic
shortcomings with regard to the implementation of the responsibility (Dublin) rules in
Member States benefitting from solidarity measures, in particular deficiencies that could
result in serious negative consequences for the functioning of the Dublin system. Where such
a situation is identified by the Commission, the contributing Member States are not required
to implement their solidarity pledges or to apply responsibility offsets.
The first meeting of the Technical-Level EU Solidarity Forum will take place early in 2026.
The finalisation of the terms of reference and of the rules of procedure is ongoing. The EUAA
is in the process of developing a practical guide on the implementation of the solidarity
mechanism in relation to relocations and responsibility offsets.
3.9 Building Block 8 - Preparedness and contingency planning
Contingency planning is an instrumental part of the Pact, guaranteeing that the asylum and
reception systems can continue to function properly and adapt quickly to sudden changes in
the migratory situation.
To support Member States during the preparations of their contingency plans, as required by
the Reception Conditions Directive, in November 2024 the EUAA developed the template
that Member States must use. It also issued a manual of examples and good practices and
organised a series of training webinars. In March 2025, the European Migration Network
(EMN) organised a capacity building workshop on scenario modelling and contingency
planning for Member States. More broadly, to intensify the technical exchanges on different
aspects of contingency planning on migration, the Commission reactivated a dedicated sub-
group on contingency planning within the framework of the Migration Preparedness and
Crisis Blueprint Network.
The legal deadline for submitting the national contingency plans to the EUAA was 12 April
2025. To date, 22 Member States have adopted and notified their contingency plans (46
).
Key challenges and next steps
Member States that have not yet done so should notify their contingency plans to the EUAA
as a matter of urgency.
Most of the plans notified to the EUAA include the core elements of the template, albeit with
different levels of completeness. Member States are invited to ensure that concrete measures
(46
) 26 Member States are required to submit national contingency plans to the EUAA. Czechia, Poland and the Netherlands
informed the EUAA of delays. Hungary provided no information.
EN EN
are outlined for all elements of the template (e.g. asylum, reception and unaccompanied
minors), underpinned by well-defined scenarios and indicators, as well as preparedness
measures.
All Member States also need to maintain the plans fit for purpose, update and revise them and
test them when possible. It is also important to ensure coherence with other contingency plans
relevant for migration (e.g. on borders or return). Moreover, practical preparedness measures
(e.g. logistics and procurement preparation, stockpiling, training or buffer reception capacity)
should be taken to ensure capacities can be mobilised in a flexible and efficient manner. The
Commission will provide information on the level of preparedness in the Union and in the
Member States in the Annual Report in October, based on input from the EU agencies, in
particular Frontex and the EUAA. From 2026 onward, contingency planning on reception and
asylum will be assessed as part of the EUAA multiannual monitoring programme.
3.10 Building Block 9 - New safeguards for applicants for international protection
and vulnerable persons, and increased monitoring of fundamental rights
The Pact strikes an important balance not just between solidarity and responsibility, but also
between the obligations and rights of people seeking protection in the EU. It introduces new
elements related to the independent monitoring of fundamental rights during screening and
the asylum border procedures, reinforced procedural safeguards and protection measures,
such as free legal counselling and information provision, and includes clear and reinforced
provisions for people with vulnerabilities or special reception needs, notably children,
including unaccompanied minors. While some gaps remain, Member States’ Nationals
Implementation Plans generally reflect the overall balance between rights and obligations and
incorporate these new elements. It is important that this continues to be the case throughout
the full implementation process, in legislation and during operationalisation and resource
allocation.
In support of Member State’s implementation, clarification and guidance on the relevant legal
provisions were provided in the expert committee meetings. In September 2024, the
Commission organised a dedicated meeting with Member States that focused specifically on
the implementation of the provisions and specific safeguards relating to children, including
unaccompanied minors, across all the new legislative instruments.
As required by the Screening Regulation (47
), the EU Fundamental Rights Agency issued
guidelines on the Independent Fundamental Rights Mechanism to Member States in
September 2024 (48
). Those guidelines focus on the different elements of the mechanism in
helping to prevent rights violations, protect victims and support investigations into allegations
of wrongdoing by public authorities.
The EUAA is drafting the relevant information provision material, and the Practical Guide on
Information Provision in the Asylum Procedure will be finalised in 2026. In relation to
vulnerability, the EUAA has issued relevant practical guides regarding the assessment of the
mental health of applicants for international protection, applicants with diverse sexual
(47
) Regulation (EU) 2024/1356 of the European Parliament and of the Council of 14 May 2024 introducing the screening of
third-country nationals at the external borders and amending Regulations (EC) No 767/2008, (EU) 2017/2226, (EU)
2018/1240 and (EU) 2019/817, OJ L, 2024/1356, 22.5.2024, ELI: https://eur-lex.europa.eu/eli/reg/2024/1356/oj/eng.
(48
) Monitoring fundamental rights during screening and the asylum border procedure – A guide on national independent
mechanisms: https://fra.europa.eu/sites/default/files/fra_uploads/fra-2024-independent-border-monitoring-
mechanisms_en.pdf.
EN EN
orientations, gender identities, gender expressions and sex characteristics (49
). Still this year,
the EUAA is expected to publish an update of the 2019 Practical Guide on the Best Interest of
the Child in Asylum Procedures, the Best Interests Assessment tool and a package of child-
friendly information about the asylum procedures and specific safeguards available to
children. The EUAA is also working on the revision of various training modules related to
vulnerable applicants, such as the module on children in the asylum process, the module on
victims of Gender-Based Violence and the module on reception of vulnerable persons. The
work on the revision of the EUAA Guidance on vulnerability in asylum and reception is
underway and is expected to be concluded before mid-2026.The EUAA will publish and
update of the 2018 guidance on age assessment still this year.
Most Member States provide for the establishment of the independent Fundamental Rights
Monitoring Mechanism in their NIPs, and some are already in contact with existing national
bodies and potential providers (50
). Similarly, most Member States either already have free
legal counselling during the administrative stage or have included it in their plans (51
).
Member States are also preparing adaptations to the assessment and dedicated support for
people with vulnerabilities or special procedural needs. This may include revising the
Standard Operating Procedures care manuals or the active establishment of new partnerships
for related tasks, as for example is foreseen in Ireland, as well as increased staffing. Several
Member States are also anticipating the creation of more dedicated reception spaces for
vulnerable people, including families (52
).
A number of Member States have taken steps to prepare for the implementation of the new
multi-disciplinary age assessment process and put in place the necessary reforms of their
system for providing guardians or legal representatives to unaccompanied minors in line with
the new requirements. In some Member States this means reviewing procedures for the
designation of representatives for unaccompanied minors, while other are now developing or
strengthening procedures and guidance for the assessment of the best interests of the child and
the related follow-up.
Key challenges and next steps
A general challenge across this building block relates to the need to coordinate with different
partners and entities, be it for legal aid, education, social welfare or health, to put in place the
operational arrangements required. Various Member States have also flagged challenges
related to the reforms relating to minors (53
) and to the requirements relating to vulnerability
assessment and subsequent support. Other Member States continue to face a lack of suitable
(49
) Practical guide on applicants with diverse sexual orientations, gender identities, gender expressions and sex
characteristics – Cross-cutting elements: https://euaa.europa.eu/publications/practical-guide-SOGIESC-cross-cutting-
elements; Mental Health and Well-being of Applicants for International Protection Part I:
https://euaa.europa.eu/sites/default/files/publications/2024-11/Practical-guide-mental-health-well-being-applicants-part-
i-senior-management.pdf; Mental Health and Well-being of Applicants for International Protection Part II:
https://euaa.europa.eu/sites/default/files/publications/2024-11/Practical-guide-mental-health-well-being-applicants-part-
ii-first-line-officers.pdf.
(50
) Some 23 Member States provide relevant information in their NIPs, although details are lacking for some of them.
Issues have already been flagged, including for Bulgaria, Italy and Malta. Austria and Greece make no reference to it.
(51
) Some Member States already have free legal counselling in place: Germany, Belgium, Croatia, France, Portugal, though
adaptations are needed. Some 18 Member States foresee it in their NIPs. It is not yet in place in Greece, Hungary,
Poland.
(52
) These include for example Cyprus, Latvia, Malta and Slovenia.
(53
) For example, relating to the process of appointing representatives for unaccompanied minors and ensuring sufficient legal
guardians: Estonia, France, Latvia, Lithuania.
EN EN
reception places for people with special needs, including children and/or lack of reception
places in general (54
).
Over the next months, Member States should work to ensure that the national entities for
monitoring fundamental rights are defined and designated, that their independence is
guaranteed, and that the relevant cooperation arrangements are set up (55
). Member States
should also ensure adequate resources for the fundamental rights monitoring mechanism and
free legal counselling ensuring, through recruitment and training, the necessary capacity and
that a quality control mechanism is in place if such services are outsourced. Member States
should also ensure a sufficient number of well-trained representatives for unaccompanied
minors, in accordance with the Asylum Procedure Regulation. In many cases, this may
require reaching out to the other relevant national authorities and ministries. Member States
where plans still need to be established or confirmed must urgently do so to avoid further
delays in the operationalisation (56
).
3.11 Building Block 10 - Integration and legal pathways to protection
Effective integration and inclusion policies are important for a well-managed migration and
asylum policy, helping to ensure social cohesion. In this way, migrants can support
themselves and contribute to society and the economy as well as the EU’s competitiveness.
Several Member States addressed the need to invest more or continue their efforts to support
the integration of beneficiaries of international protection in their National Implementation
Plans. This includes developing early integration measures and a more efficient process for
the recognition of qualifications and the validation of skills. Effective access to housing
remains a challenging issue (57
).
The EU supports Member States in their integration efforts through funding, developing
guidance and fostering multi-level partnerships involving migrants, host communities, social
and economic partners, civil society and the private sector (58
).
In November 2020, the Commission adopted an Action Plan on Integration and Inclusion
2021-2027 (59
), as one of the first actions when putting forward the Pact. Alongside this
Communication, the Commission is presenting a staff working document reviewing the
implementation of the Action Plan at mid-term and identifying good practices, remaining
challenges and areas where further work remains to be done. The review also provides
insights and tools on the integration of persons in need of protection with a view to assisting
Member States with the operationalisation and implementation of the Qualification
Regulation (60
) and of the Reception Conditions Directive, including measures for early
integration of international protection applicants and beneficiaries.
(54
) For example, Belgium, Greece, Latvia, Lithuania, the Netherlands and Cyprus.
(55
) See also: https://fra.europa.eu/sites/default/files/fra_uploads/fra-2024-independent-border-monitoring-
mechanisms_en.pdf.
(56
) For example, Austria, Belgium, Denmark, Greece, Poland and Hungary.
(57
) This was also a key topic for deliberation at the last bi-annual meeting of the EUAA Network of Contact Points on
Reception (May 2025).
(58)
Examples include the European Integration Network, which unites representatives from national public authorities
responsible for migrant integration in all 27 Member States, as well as Iceland and Norway; the Expert Group on the
views of migrants; the Committee of the Regions partnership on the Integration of Migrants; the Urban Agenda
Partnership on Inclusion, which brings together partners from different governance levels.
(59
) Communication from the Commission to the European Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions Action plan on Integration and Inclusion 2021-2027, COM(2020) 758
final, EUR-Lex - 52020DC0758 - EN - EUR-Lex.
(60
) Regulation (EU) 2024/1347 of the European Parliament and of the Council of 14 May 2024 on standards for the
qualification of third-country nationals or stateless persons as beneficiaries of international protection, for a uniform
status for refugees or for persons eligible for subsidiary protection and for the content of the protection granted,
EN EN
On legal pathways to protection, the work on the implementation of the Union Resettlement
and Humanitarian Admission Framework Regulation (61
) is advancing. In line with the
voluntary nature of the instrument, Member States have assessed their needs to amend
existing programmes and workflows to align with the novelties brought by the Regulation.
The Commission convened three meetings of the Resettlement Expert Group to exchange on
specific provisions of the Regulation and their implementation. The EUAA Resettlement and
Humanitarian Admission Network meetings also discussed the operational support that
Member States may require when carrying out their programmes under the new rules. To
prepare the first Union Resettlement and Humanitarian Admission Plan, the Commission
convened two meetings of the High-Level Resettlement and Humanitarian Admission
Committee, where participants exchanged on priorities.
Key challenges and next steps
The mid-term review of the Action Plan on Integration and Inclusion shows that migrant
integration outcomes have overall improved since 2021. At the same time, challenges persist
in all the four main areas of intervention: education, employment, health and housing (62
).
Maintaining targeted interventions towards beneficiaries of international protection remains
necessary, particularly for women, children and persons with specific needs. The mid-term
review also highlights the importance of a more integrated approach and closer coordination
between the different levels of governance of the Member States, notably regarding financial
planning and support. Finally, the mid-term review also acknowledges the challenges faced
by the Member States to strike the right balance between migrants’ integration and the
welfare of their own populations. Going forward, the Commission will take on board the
lessons learnt from the mid-term review of the Action Plan.
More generally, in already stressed housing markets, lack of access to housing for
beneficiaries has consequences on reception capacity because it makes it more difficult to free
up reception places. In addition, simplification and reducing delays in providing residence
permits and other necessary documentation to beneficiaries is also a target for a few Member
States.
Resettlement and humanitarian admission are an important contribution to a sustainable and
comprehensive approach to migration management. Following the indications at the High-
Level Committee and the preliminary contributions set forth by the Member States, the
Commission will present its proposal for the Union Resettlement and Humanitarian
Admission Plan by the autumn. The Union Plan aims to serve as a strategic tool to further
embed the Union’s resettlement and humanitarian admission efforts within comprehensive
partnerships and dialogues with key third countries. Following the Commission proposal, the
Council and the Member States will finalise the Union Plan and work towards its adoption by
the Council before the end of 2025, for a timely implementation in 2026 - 2027.
4. CONCLUSION AND NEXT STEPS
Half-way through the transition period, important progress has been made both at Union and
national level. However, a steady pace must be maintained and, in several instances,
accelerated to address the challenges that remain across all building blocks.
amending Council Directive 2003/109/EC and repealing Directive 2011/95/EU of the European Parliament and of the
Council, OJ L, 2024/1347, 22.5.2024 Regulation - EU - 2024/1347 - EN - EUR-Lex.
(61
) Regulation (EU) 2024/1350 of the European Parliament and of the Council of 14 May 2024 establishing a Union
Resettlement and Humanitarian Admission Framework, and amending Regulation (EU) 2021/1147, OJ L, 2024/1350,
22.5.2024 Regulation - EU - 2024/1350 - EN - EUR-Lex.
(62
) For more details, see Commission Staff Working Document on the mid-term review of the Commission Action Plan on
Integration and Inclusion 2021-2027 accompanying this communication.
EN EN
Maintaining this positive momentum and continuing to work together will ensure a
streamlined and coordinated process, while enabling critical interdependencies across the
various workstreams to be monitored effectively. Keeping track of the implementation will
require continuous exchange of information, promoting mutual learning and sharing of good
practices. To facilitate this, the Commission will promote a more structured and transparent
exchange of information and provide targeted support to Member States facing challenges. In
parallel, attention will be given to simplifying processes and mitigating administrative
burdens where possible, to ensure that efforts remain focused, efficient and result oriented.
The Commission will also continue its engagement with Member States on a bilateral basis to
provide tailored support for the implementation of the Pact.
The first annual solidarity cycle starting in October 2025 makes it even more important to
address existing challenges, to ensure that there are no significant shortcomings in the
application of the current rules, including in the Dublin system and on reception, and that
continuous progress is made in the implementation of the Pact. Being well prepared underpins
the obligations under the Pact, also serving as a baseline for Member States to be considered
under migratory pressure, facing a significant migratory situation or facing a crisis, and for
having access to the Solidarity Pool.
An important deliverable will be the adoption of a five-year European Asylum and Migration
Management Strategy by December 2025. This Strategy will build on the national strategies
that Member States need to adopt and transmit to the Commission by 12 June 2025, covering
both the internal and external dimensions of migration in a comprehensive and integrated
approach.
To complement and support the sustainable implementation of the Pact, the Commission will
continue its work on the external dimension of migration policy, notably on comprehensive
partnerships with third countries, in a Team Europe spirit and following a whole-of-route
approach. Focus will be put, among others, on decreasing irregular arrivals to the EU, on
fighting migrant smuggling and on increasing the efficiency of our return efforts.
The success of the system will rely on the commitment and readiness of all Member States
across all building blocks, as actions in one area can have wider implications for all. The
Commission and the EU agencies will continue supporting Member States in their efforts and
count on their constructive and sustained engagement. At the same time, recalling that any
legal framework is only as effective as its implementation, the Commission will carefully
monitor progress and stands prepared to use the appropriate procedures in line with the
Treaties to ensure compliance. This underscores the shared political responsibility of all to
fully commit to the Pact’s objectives.
The Commission will present the next state of play on the implementation of the Pact to the
European Parliament and the Council as part of the Annual Report on Migration and Asylum
in October.