Testing the Applicability of EU Law Abroad: The Italy–Albania Protocol in the Comeri, Sidilli, and Sedrata Hearings

 

Eleonora Celoria, Post-doctoral researcher, FIERI

Andreina De Leo*, Post-doctoral researcher, Maastricht University

Marcella Ferri, Research Fellow, Florence University

* Funded by the European Union (ERC, SoftEn project, 101165167, PI: Lilian Tsourdi). Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the European Research Council. Neither the European Union nor the granting authority can be held responsible for them.

Photo credit: Jorge Franganillo, via Wikimedia Commons

Introduction

On 23 and 24 March 2026, the Court of Justice of the European Union (CJEU) held two hearings in the ongoing proceedings addressing the compatibility of the Italy-Albania Protocol with EU law and the broader implications of conducting asylum and return procedures extraterritorially (Joined cases C-706/25 Comeri and C-707/25 Sidilli, and C-414/25 Sedrata).

This may appear as a déjà-vu. Less than a year ago, the extraterritorial processing of asylum under the Italy-Albania Protocol had already come before the Court in the well-known Alace and Canpelli cases (discussed on this blog by Zamboni and Favilli & Marin). The focus of those cases was, however, narrower, as it concerned the criteria to designate countries as “safe countries of origin” under the Asylum Procedures Directive (APD) and their judicial review, a classification that directly enabled the use of accelerated offshore asylum procedures in Albania. Following those rulings, the Italian Government adjusted its strategy, implementing a policy based on the relocation to Albania of returnees already detained in Italian pre-removal detention centers under the Return Directive (RD). While awaiting removal, these individuals may lodge an asylum application which, according to the Government, can then be examined in Albania. Against this backdrop, the new preliminary references raise a distinct and more direct question: whether asylum and return procedures can, as such, be carried out in a third country without breaching EU law. In doing so, they place the legality of the Protocol as a whole squarely before the Court.

More specifically, the first preliminary ruling, submitted by the Court of Cassation on 20 June 2025, asks whether Articles 3, 6, 8, 15, and 16 of the Return Directive preclude transferring a migrant subject to a return order to an extraterritorial detention centre, even without a concrete prospect of removal. It also asks whether Article 9(1) of the Asylum Procedures Directive, which requires applicants to remain on a Member State’s territory, precludes keeping asylum seekers who lodge an asylum application after being transferred to a third-country detention centre within that country (see De Leo).

The second preliminary ruling, submitted by the Rome Court of Appeal on 5 November 2025, directly questions Italy’s competence to conclude an international agreement  interfering with an area of exclusive EU competence, as laid down in Articles 4(3) TEU, 3(2) TFEU and 216(1) TFEU (see Montaldo and delli Carri). Alternatively, should the Court find that Italy has such competence, it asks whether the safeguards under the APD and the Reception Conditions Directive (RCD), as well as the Charter, particularly the rights to liberty, an effective remedy, and health, preclude transferring asylum seekers to, and detaining them in, centres outside EU territory.

It is worth recalling that the stated aim of the Protocol is to “reinforce bilateral cooperation in managing migration flows,” allowing Italy to transfer migrants to Albania solely to carry out asylum and return procedures under Italian and EU law (Art. 4(3) Protocol). These procedures remain under Italian jurisdiction and are conducted in accordance with national and EU law “to the extent compatible” (Art. 4(1), Ratification Law 14/2024).

Although raising different questions, both Italian courts focused on the same core issue: whether EU law safeguards can be effectively ensured for asylum seekers and returnees detained in a third country and whether those standards are compromised merely because detention occurs outside the territory of a Member State.

Outline of the post

While awaiting further developments, and notably the Advocate General’s opinions on 23 April (Sedrata) and 11 June (Comeri and Sidilli), this post examines the key issues raised during the hearings and outlines the main arguments on whether asylum and return procedures conducted in a third country, yet under a Member State’s jurisdiction, comply with EU law.

It first considers whether EU law applies to procedures carried out in Albania and whether such procedures may interfere with its application, summarising the positions of the Italian Government and the European Commission. Two aspects are examined: the Dublin system and its founding principle of mutual trust, and whether EU safeguards can be effectively guaranteed in detention centres abroad. Finally, the post clarifies the differences between the Albania model, the so-called “return hubs,” and the notion of a safe third country, as frequently referenced during hearings and in public debate.

EU Law Beyond Territory: Parties’ Arguments on Applicability, Compliance, and Competence in the Italy-Albania Scheme

The Italian government

To justify the compatibility of the Italy-Albania Protocol and its Ratification Law with EU law, the Italian Government advanced two alternative lines of argument. Both were aimed at demonstrating that: first, the Protocol does not risk adversely affecting the internal rules of the Union and therefore does not encroach upon an area of exclusive EU competence; secondly, that the extraterritorial application of the relevant directives in a third country does not undermine their effet utile.

First, the Government argued that the Albanian centres should be considered “representations of Member States” abroad under the APD and RCD, and that EU law applies indirectly through its incorporation via the Ratification Law. On this basis, the Government maintained that the Italy-Albania Protocol is purely technical and logistical: it does not alter the substance of the legal framework on pre-removal detention, asylum procedures or reception conditions, which remain fully applicable because the legislator has chosen to extend EU standards to the situations covered by the Protocol. By virtue of this legal extension, the Government maintained that third-country nationals detained in Albania receive treatment equivalent to that in Italy. It further argued that instruments such as the Dublin Regulation, though not explicitly mentioned in the Protocol, continue to apply because the individuals remain continuously under Italian jurisdiction. Accordingly, the Protocol would neither interfere with the Common European Asylum System (CEAS) nor encroach upon the Union’s external competences.

With respect to the RD, the Government argued that the transfer to Albania does not qualify as a “return” within the meaning of Article 3, but it rather amounts to a temporary relocation to a different pre-removal detention facility, legally assimilated to ones located on Italian territory. Accordingly, it maintained that compliance with the Directive’s objectives and provisions, including Articles 15 and 16 on detention and conditions of detention, are not undermined, as the material conditions would be fully respected. Regarding the APD, the Government contended that Article 9 is not violated when returnees apply for asylum after being transferred to Albania, since they remain under Italian jurisdiction, and thus do not risk refoulement, and continue to benefit from the full application of both the APD and RCD.

Alternatively, the Government argued that EU law could apply directly through a functional interpretation of “territory.” In the absence of a clear EU definition of “border” or “transit zones,” the centres in Albania could be regarded as a fictio iuris, functionally equivalent to transit zones located on Italian soil. On this view, the legal equivalence of procedures in Albania and Italy would justify treating the Albanian centres as falling within the scope of EU law, in the same way as their territorial counterparts.

While the Dublin Regulation was not explicitly mentioned by the referring judges, it emerged as a contentious issue. In particular, the risk of circumventing Dublin criteria for unaccompanied minors (Article 8) and family members (Articles 9–10) was debated during the Sedrata hearing. The Italian Government maintained that the Regulation remains applicable because the Albanian centres qualify as “transit zones” under Dublin III. This, however, raised a fundamental question from the bench: on what legal basis could another Member State be required to accept a Dublin transfer from a non-EU centre, and how would this not interfere with common EU rules? Questions which were left unresolved.

The European Commission

The Commission, by contrast, adopted a strict literal reading of the directives, distinguishing clearly between jurisdiction and territory. While acknowledging that the individuals remain under Italian jurisdiction, it stressed that asylum and reception rules are territorially anchored and do not apply automatically outside Member State territory. Nonetheless, the Commission did not view the Protocol as violating EU law or encroaching on exclusive EU competences, so long as the legislator’s choice to apply EU standards effectively preserves the effet utile of the acquis. Its reasoning followed two separate lines, depending on the instrument in question.

As for the RD, the Commission noted that it does not strictly define its scope in territorial terms but rather sets standards to ensure the effectiveness of returns from EU territory. Since Italy has committed to applying these standards in Albania, the Commission did not see any inherent incompatibility with the temporary transfer of returnees outside the territory pending repatriation. Yet, this conclusion was subject to strict conditions: the Commission emphasised that detention should have been previously judicially authorised, that all guarantees under Articles 15–18 of the Directive are fully respected, and that the transfer to Albania must not constitute the execution of the return decision. In essence, for the Commission the Directive does not require detention to occur on the territory of the Member State: what is rather decisive is that the Member State fully complies with its concrete obligations.

As for the APD and the RCD, the Commission rejected the qualification of the Albanian centres as “transit zones.” It stressed that the notion of territory is autonomous under EU law and cannot be extended to third countries, and that thus a “transit zone” must be located within the Union’s territory. When pressed by the bench on whether an international definition of “transit zone” exists, it indicated that this was ultimately irrelevant, as the notion must be understood as a matter of EU law. Accordingly, the Protocol cannot extend EU territory, and the direct applicability of the asylum acquis is thus excluded.

That said, the Commission did not view the mere extension, via national law, of EU standards to procedures in Albania as automatically undermining the directives’ objectives or interfering with internal EU competences under the ERTA doctrine. Such a violation would only arise if the arrangement risked affecting common EU rules: a risk the Commission considered unproven here. Article 9 APD illustrates this approach: if the asylum application is made in Italy, transfer to Albania is precluded. Conversely, if lodged only after transfer, while the Directive does not apply directly, its purpose, i.e. to prevent removal before assessing refoulement risks, is fulfilled because Italy retains jurisdiction and applies EU standards.

Regarding the Dublin system, the Commission held that the Regulation does not apply outside EU territory, revealing a potential paradox noted by Advocate General Emiliou during Sedrata: if EU law does not formally apply, can it still be circumvented?

More broadly, the question arises whether exclusion from the scope of the Regulation and Directives is merely a consequence of its incidental inapplicability in a third country, or the result of a deliberate choice by Italy, and namely, transferring individuals to Albania. In the latter scenario, how can it be argued that the Protocol and Ratification Law do not effectively allow Italy to evade its obligations under EU law?

As President Lenaerts highlighted, the key concern of the ERTA doctrine is preventing Member States from using external bilateral agreements to regulate matters that fall within EU law, in ways that could undermine its objectives. In other words, it is not enough to claim that EU law does not directly apply in a third country, but what matters is whether the external action could affect the effective internal functioning and uniformity of the EU legal framework. In this respect, the Commission’s position appeared unsatisfactory, as it failed to address the broader systemic implications for the CEAS and the structural risks of circumvention inherent in the scheme.

This brings us to our legal assessment, where we examine the unresolved issues in the approaches of the Italian Government and the Commission regarding the challenges of extraterritorialising asylum procedures and applying EU law in a third country.

Assessing the Potential Interference of Procedures Conducted in a third country with the EU Migration and Asylum Acquis

All in all, both the Italian Government and the European Commission ultimately arrive at a broadly similar conclusion: the Italy-Albania Protocol does not entail a violation of the Union’s exclusive competences, nor does it compromise the effet utile of the relevant directives, insofar as EU standards can be ensured, even in a third country. However, this conclusion leaves several key issues unresolved. First, it does not fully address the implications for the Dublin system. Indeed, the extension of Dublin obligations outside the Union could highly interfere with the CEAS and the principle of mutual trust. Second, the assumption that equivalent standards can be guaranteed extraterritorially remains highly problematic, as the territorial scope of EU asylum law reflects structural constraints necessary to ensure full compliance with procedural and substantive guarantees. These two issues will be addressed separately in the following sections.

The (application of the) Dublin system: a paradigmatic interference with the CEAS

The application of the Dublin system emerged as a highly sensitive issue during the Sedrata hearing. While EURODAC was not discussed, the reasoning for the Dublin Regulation can be extended to it, in light of recital 54 of EURODAC Regulation. The Italian Government and the Commission took sharply divergent positions: the Government qualifies the centres as “transit zones” under Dublin, a view opposed by the Commission, which raises several critical questions.

First, how can the Albanian centres be considered “representations of Member States” under the APD and the RCD, or “transit zones” under the Dublin Regulation? This argument is unpersuasive, as it would imply that the notion of “transit zone” differs across two CEAS instruments, risking to undermine the system’s internal coherence.

Secondly, if the Dublin system were applied to asylum requests lodged in the Albanian centers, other Member States would be obliged to accept transfers, as the Italian Government argued. From a theoretical perspective, this would directly interfere with the CEAS and undermine the principle of mutual trust on which it rests (Lenaerts, 2017). In fact, the presumption of compliance with EU law standards appears questionable in itself when it is applied to an asylum request lodged outside the territory of a Member State — albeit under its jurisdiction. Yet, save for specific exceptions, that principle prevents other States from verifying whether, in a given case, Italy has actually complied with EU law in processing an asylum application, notably that it has allocated responsibility in accordance with the procedural guarantees laid down in the Dublin Regulation and with the right to an effective remedy against the transfer decision. In short, extending the Regulation to applications lodged in the Italian centres in Albania would run counter to the principle of mutual trust underpinning the Dublin system and, ultimately, the CEAS.

Third, from a practical perspective, applying the Dublin Regulation outside Italy would adversely affect the rights of asylum seekers lodging an application in another Member State and seeking reunification with a family member detained in Albania (Article 10 of the Dublin Regulation). Unless the applicants were also transferred to Albania — which would amount to their de facto detention — they would remain in Italy, thereby rendering effective reunification  impossible. This impossibility, which stems directly from the detention of the family member in Albania rather than in a detention facility on Italian territory, would breach their rights to family life and to the child’s best interests, as laid down in the Dublin Regulation and in Articles 7 and 24 of the Charter.

By contrast, if, as the Commission argues, the Dublin Regulation does not apply, Italy could evade its obligations under Articles 8— 10 of the Regulation and Articles 7 and 24 of the Charter. Once again, such circumvention would be achievable simply through the deliberate extraterritorialisation of asylum procedures. In a nutshell, whether applied or not, the Dublin Regulation illustrates the systemic and structural interference with the CEAS created by the Protocol and Ratification Law.

Ensuring Effective Application of  EU Standards and Rights in a Third Country: Mission Impossibile?

We concur with the Commission that the territorial nature of EU asylum law imposes inherent limits on extending its directives beyond the Union. However, we diverge from the view that voluntarily applying EU standards abroad via national law automatically resolves compatibility concerns. This divergence is anchored in the structural reality that the territorial scope of the directives is not merely formal: it reflects the impossibility of fully guaranteeing procedural and material standards outside the Union. Applying EU law where these guarantees cannot be secured risks undermining the directives’ objectives, the uniformity of EU law, and may raise concerns under the ERTA doctrine (see: De Leo & Celoria, and Montaldo).

As highlighted by the referring judges and the lawyers representing the migrants, a central issue is the gap between the guarantees afforded to migrants detained in Italy and those in the Albanian centres. The Government asserts that procedures in Albania are identical to those in Italy, yet legal equivalence on paper does not ensure effective protection in practice. In our view, the fiction that Albanian centres are legally treated as part of a Member State is insufficient to secure genuine compliance with EU standards on the ground.

The main concerns identified by the referring courts and discussed during the hearings include: the right to liberty under Article 6 of the Charter, notably the requirement for immediate release if detention is unlawful; guarantees related to detention conditions, including access for lawyers, family members, national, international, and non-governmental organisations, and access to healthcare; and the right to a fair trial and effective remedy under Article 47, particularly the right to be “advised, defended, and represented.” As emphasized by the rapporteur judge of Comeri and Sidilli case, these discrepancies risk creating a distinction between “two types of asylum seekers,” or even “two types of detainees,” solely based on where and when an application is lodged.

Both the RD and the RCD require that a person “shall be released immediately” if detention is found unlawful (Article 15(1) RD; Article 9(3) RCD). This requirement is inherently impossible to reconcile with the Italy–Albania scheme. Under Article 6(2) of the Protocol, Italian authorities must “take the necessary measures to ensure the permanence of migrants within the areas, preventing their unauthorised exit into the territory of the Republic of Albania, both during and after the completion of administrative procedures, irrespective of the final outcome.” In practice, release on Albanian territory is impossible: individuals can only be freed once transferred back to Italy. Therefore, even when detention is considered unlawful, the person remains under continuous coercive control throughout the transfer, i.e. from the detention center to the port, during maritime transport, and until release in Italy (typically in Bari or Brindisi): a process that may last from 24 hours to several days, depending on logistical conditions. In this respect, the Italian National Guarantor has recently noted that, if transfer cannot occur the same day, the person remains in a “separate area” of the same detention centre, a practice arguably failing short of the “immediate release” requirement. During this period, individuals are subject to a “coercive measure that deprives [them] of [their] freedom of movement and isolates [them] from the rest of the population” (CJEU, FMS, para. 223). Both the Albanian centres and the transport arrangements display the defining features of detention: a closed, restricted space where movements are limited and monitored and exit is not voluntary (CJEU, FMS, para. 231). The European Court of Human Rights similarly confirms that confinement on ships may constitute de facto detention, even if nominally for the person’s interest (Khlaifia and Others v Italy, paras. 70–71). In sum, the extraterritorial setting alters the legal consequences of detention, making immediate release practically unfeasible and raising serious questions about compliance with EU law.

Extraterritoriality also affects effective access to detention centres. Under national law implementing EU standards (Articles 16(2) and (4) RD; Article 10(4) RCD), a wide range of actors, e.g. parliamentarians, national monitoring bodies, UNHCR representatives, lawyers, family members, religious ministers, and civil society organisations, should be granted access (Articles 21 DPR 394/99; 7 D.Lgs. 142/2015; Ministerial Directive 19 May 2022). By contrast, Article 9(2) of the Protocol limits access to “lawyers, their assistants” and “international organisations and EU agencies,” raising questions about the interplay of the two regimes. Even if Italy seeks to apply its broader framework, as argued during the hearing, effective implementation depends on Albanian authorities’ consent. This is because access requires entry into Albanian territory, which remains under Albanian sovereignty. Article 9(2) subjects access to “applicable EU, national and Albanian law,” while Article 6(1) confirms Albanian responsibility for public order and security outside the centres and during transfers. Consequently, Albania may lawfully restrict access based on domestic entry, residence, or public order rules, limiting in practice the actors able to monitor detention conditions. While the Italian Government argued that this poses no practical concern, citing visa-free entry for holders of Italian passports or residence permits, the effectiveness of EU law guarantees cannot depend on conditions outside the Member State’s control. Making access contingent on the rules or discretion of a third country introduces uncertainty incompatible with the requirement to ensure EU rights in an effective and uniform manner. Moreover, denials imposed by Albanian authorities cannot be effectively challenged before an Italian court, which undermines the right to an effective remedy for those having the right to access the detention centres.

Similarly, under Article 10(4) of RCD, lawyers, family members, and civil society organisations have the right to communicate with and visit detainees, and any limitations must not make access impossible or excessively difficult. In the Albanian centres, however, restrictions appear structural and generalised rather than exceptional, making them difficult to reconcile with Articles 7 and 47 of the Charter and the proportionality requirement under Article 52(1). The Government’s argument that similar limitations exist in Italy is unpersuasive: in Albania, restrictions are the norm, access is more complex, time-consuming, and costly, and a recent monitoring report by the Italian National Guarantor for the Rights of Persons Deprived of Liberty notes that some detainees were not informed of their transfer, further hindering visits. Crucially, as noted above, the ultimate decision rests with Albanian authorities, meaning that limitations stemming from a third State’s sovereignty cannot be effectively challenged or remedied in Italy, thereby weakening the effective enjoyment of EU-law-derived rights.

Additionally, discrepancies in safeguards for lawyers are particularly pronounced. In Italy, appointed lawyers can access detention centres without prior authorisation and often be appointed in person after initial telephone contact. In Albania, this is not possible, nor foreseen by the Protocol or the Ratification Law, which allows travel at public expense only “when remote connection is not feasible” during the detention validation hearing (Article 4(5), Law 14/2024). This effectively precludes in-person meetings before or after the hearing to prepare a defence or appeal a negative decision. Given the current five-day deadline to challenge a validation decision, detainees without immediate lawyer access face heightened risk of ineffective representation. In-person meetings are often essential to identify vulnerabilities or health conditions that may render detention unlawful, tasks difficult to perform remotely, particularly when access depends on the private centre manager’s discretion and mobile phone use is restricted. Physical distance, limited contacts, and communication restrictions materially weaken lawyer-client interaction, undermining the right to effective assistance and representation under Article 47 of the Charter. Remote hearings further exacerbate these issues. By analogy with the Court’s reasoning in FP and Others (C‑760/22), videoconference participation is not inherently incompatible with a fair and public hearing, but its appropriateness depends on the individual being able to follow proceedings, be heard without technical obstacles, and communicate effectively and confidentially with their lawyer. In Italy, lawyers attending remote validation hearings can choose to be in the courtroom with the judge or at the centre with their client: a flexibility that is simply unavailable for detainees in Albania, further undermining effective representation.

Finally, significant disparities exist regarding the right to health, guaranteed under Article 16(3) RD and Article 17(2) RCD. Detainees in Albania face substantial limitations in medical services, particularly psychiatric and addiction care. Unlike in Italy, where detainees are integrated into the National Health System, no equivalent framework operates in Albania, and on-site medical teams cannot provide comparable treatment. These deficiencies have already led to serious consequences, including self-harm and suicide attempts (see, report, here). A recent report by the National Guarantor for the Rights of Persons Deprived of their Liberty found that, of 26 detainees for whom updated medical assessments were requested, 25 were deemed unfit for detention and released, highlighting the centres’ inadequacy to ensure proper care. While Article 4(8) of the Protocol obliges Albanian authorities to provide treatment in emergencies beyond Italian capacity on site, healthcare in a third country is by definition different from that provided by a Member State’s National Health System.

Taken together, the disparities analysed above make detention in centres located in a third country significantly more burdensome than detention in Italy, casting doubts as for its compliance with the principle of proportionality. There is no justification for imposing a harsher coercive measure than would be applied in Italy, particularly as the transfer to Albania does not demonstrably enhance the effectiveness of return procedures under the RD. On the contrary, a report by the Italian National Guarantor for the Rights of Persons Deprived of their Liberty shows that only 56 of 192 individuals transferred to Albania were ultimately returned to their country of origin, representing a return rate of approximately 29%, which is lower than the general return rate.

Conclusion

In conclusion, while the Italian Government frames the issue in terms of formal equivalence between procedures carried out in Albania and those in Italy, and the European Commission emphasizes that the voluntary application of EU standards suffices to ensure compliance, our assessment shows that this approach does not adequately address the structural limitations inherent in the de facto extraterritorial application of EU migration and asylum law.

While awaiting the Court’s decision, we maintain that the strict territorial scope of EU law in this area is not merely formal but reflects a substantive requirement: it is meant to operate within the territory of Member States, where its guarantees can be fully implemented and monitored. Remaining under the jurisdiction of a Member State alone is insufficient to ensure compliance, as EU law cannot be effectively applied outside the Union without undermining its purpose, coherence, and the procedural and material protections that are inherently tied to the territorial context in which they are guaranteed.

Two key issues arise. First, if the Dublin Regulation applies to applications lodged in Albania, the Protocol and Ratification Law would undermine mutual trust and the functioning of the Dublin system, since other Member States cannot verify compliance with EU law outside the Union. Even if it does not apply, the deliberate delocalization of asylum procedures to a third country allows circumvention of EU obligations. Second, procedural and material safeguards ensured in Italy cannot be fully replicated in a third country.

Thus, in our view, relocating individuals to Albania undermines the effet utile of the CEAS, creating tangible discrepancies in treatment that formal equivalence cannot remedy. This, in turn, risks breaching the principle of loyal cooperation and jeopardizes both the uniform application of EU law and the trust-based cooperation that underpins the EU legal order.

A Final Note: Why Albania Is Different from Other Externalisation Models

Throughout the hearings, “return hubs” were frequently cited as a possible analogy to justify the legality of the Albania model. However, as repeatedly emphasized by all parties, the two schemes are fundamentally different from a legal perspective. The Commission’s proposed reform of the notion of a ‘return decision,’ which provides the legal basis for return hubs, presupposes a formal removal decision to a country other than the state of origin with which an agreement exists. In that context, the transfer constitutes an actual return under EU law (discussed, in this blog, here). By contrast, the Albania model does not involve a removal but a temporary relocation of the detention stage of the return procedure under the full jurisdiction of the Member State, prior to any formal removal to the individual’s country of origin or habitual residence. Consequently, it cannot be assimilated to the return hub framework.

Similarly, the Albania model cannot be framed within the reformed notion of a safe third country without a connection requirement (discussed, in this blog, here), as no inadmissibility decision is taken in Italy based on Albania’s acceptance of the asylum application. Instead, the procedure merely relocates the processing of the asylum claim to Albania while keeping the substantive application under Italian jurisdiction.

This distinction highlights that equating the Albania model with return hubs or safe third country schemes overlook its unique legal and procedural features. It underscores the complexity of assessing its compliance with EU law and why the pending preliminary rulings are essential to clarify the boundaries and practical limits of this peculiar migration management scheme.