Showing posts with label common European asylum system. Show all posts
Showing posts with label common European asylum system. Show all posts

Saturday, 13 December 2025

Asylum Pact 2.0: the EU moves towards more stringent rules on ‘safe third countries’ and ‘safe countries of origin’


 


Steve Peers, Professor of Law, Royal Holloway University of London

Photo credit: Steve F, via Wikimedia Commons

 

Introduction

The EU’s asylum pact, agreed in 2024, is mostly not fully in force yet; it will largely apply from 12 June 2026. But even before that date, the EU is planning to make its rules more stringent – and even to apply some of them in advance. The prospect of these planned changes moved closer recently, as both the European Parliament and the EU Council, ie Member States’ ministers firmed up their negotiation positions on two separate proposals, and may negotiate an agreed final text of them both in the near future.

This blog post summarises the proposals in their context, and then examines the proposed amendments coming from the EP and the Council, concluding with an assessment of the main issues arising from the negotiations – including the prospect of a ‘Rwanda clause’ in EU law, mirroring the last UK government’s attempt to designate that country as ‘safe’ even for asylum-seekers who had not travelled through it, and the European Parliament’s suggestion to curtail judicial review in a way that would obviously breach the EU’s Charter of Fundamental Rights.

 

Background

The EU asylum pact includes a Regulation on asylum procedures (which I previously discussed here), replacing the current Directive on asylum procedures, dating from 2013, which sets out detailed rules on the processing of asylum applications. These include rules on both supposedly ‘safe countries of origin’ (countries which asylum-seekers originate from) and supposedly ‘safe third countries’ (countries other than the countries of origin, which asylum-seekers ‘should’ apply for asylum in instead).

Variations of these two concepts have existed in EU law for a long time, dating back initially to 1992 in the form of the London Resolutions of Member States’ ministers (see here and here). The concepts then appeared in the initial 2005 asylum procedures Directive, since replaced by the 2013 version of the rules. Although the asylum pact Regulation adopted in 2024 made these rules more restrictive for asylum-seekers, this was deemed insufficient, hence the move to change the rules in the pact already.

 

‘Safe countries of origin’

Current rules

The 2013 rules provide that a country can be considered a ‘safe country of origin’ for non-EU asylum seekers if it meets specified human rights standards, taking account of country of origin information from various sources such as the UNHCR and EU asylum agency. Use of this rule is currently an option for Member States. The rule can only apply if an asylum-seeker is a national of the country concerned, or is a stateless person formerly habitually resident there. Member States must lay down further rules in national law if they use the concept. They must also regularly review the list of countries concerned and inform the Commission of the list.

Unlike the 2005 rules, it is not possible to define a country as safe only in part, either geographically or for selected groups of people, as the Court of Justice has recently confirmed (see here and here). These judgments put a spanner in the works – at least temporarily – of the Italy/Albania arrangements, under which Italy planned to remove to Albania select groups of asylum-seekers who came from a ‘safe country of origin’, which was designated as ‘safe’ for only some groups of people; the asylum-seekers were to remain in Albania while Italy processed their application. In the latter judgment (Alace), the Court of Justice also said that: a Member State had a choice of routes to designate a ‘safe country of origin’ in national law, but its designation must be subject to judicial review; the sources of information used for the designation must be provided to the applicant and to courts; and courts must be able to examine other sources of information.

Defining a non-EU country of origin as ‘safe’ creates a presumption, which can be rebutted by the asylum-seeker if they can show ‘any serious grounds for considering the country not to be a safe country of origin in his or her particular circumstances and in terms of his or her qualification as a beneficiary of international protection’. It is also a ground for fast-tracking the consideration of asylum applications, although the current rule does not specify a time limit to this end (just that it should be ‘reasonable’, and can be exceeded if necessary to examine the application properly). In comparison, the time limit for ‘standard’ asylum applications in the current law is six months (although there are several grounds for extending that deadline).

The ‘safe country of origin’ rule is also one ground for applying a fast-track border procedure to asylum-seekers’ applications; again, such procedures are currently optional. Here there is a specific deadline, namely to conclude the process within four weeks, otherwise the asylum-seeker must be allowed on to the territory, and (as confirmed by Court of Justice case law) released from detention if that was the only ground for it. Finally, Member States may deny suspensive effect appeals in ‘safe country of origin’ cases, although asylum-seekers must have an opportunity to request a court to grant such suspensive effect.

2024 Regulation

Under the 2024 asylum pact Regulation, applicable (as things now stand) to asylum applications made after 12 June 2026, the ‘safe country of origin’ rules become mandatory for Member States. (Most, but not all, Member States were applying them already) The basic definitions of human rights standards in the country of origin remain, as do the rules on the sources of data to be considered. But under the new rules, it will be possible to designate a non-EU country of origin as ‘safe’ in part, either geographically (exceptions for ‘specific parts of its territory’) or for some groups of people (‘clearly identifiable categories’). Conversely, there is nothing to suggest that the other aspects of the Alace judgment (on effective judicial review of designations of ‘safe third countries’) cease to apply.

One new aspect of the rules is that it is possible for the EU to adopt its own common list of ‘safe countries of origin’, via the ordinary legislative procedure. This is accompanied by rules on dropping countries from the list in the event of ‘significant changes’ there, initially by means of a delegated act adopted by the Commission, then via legislation. Member States cannot put the country back on their national list of ‘safe countries of origin’ while a delegated act suspending it from the list applies; for two years after the country is dropped from the common EU list via legislation, Member States need the Commission’s approval to reinstate it on their national lists.

A similar new ground for accelerated procedures has been added: Member States must also fast-track cases where the most recent annual recognition rate for asylum claims for the asylum-seekers’ nationality is below 20% EU-wide at first instance (ie before appeals), ‘unless the determining authority assesses that a significant change has occurred in the third country concerned since the publication of the relevant Eurostat data or that the applicant belongs to a category of persons for whom the proportion of 20 % or lower cannot be considered to be representative for their protection needs, taking into account, inter alia, the significant differences between first instance and final decisions.’

There will now be a specific three-month deadline to decide on accelerated cases, although an authority can decide to consider the asylum application on the merits if the case is too complex. (The general deadline to decide on applications remains six months; the possibilities of extending that deadline have been partly curtailed).

‘Safe country of origin’ remains a ground (alongside now the ‘20% recognition rate’ rule) for considering applications in a border procedure, but that procedure has been overhauled: it is now mandatory for Member States for a certain number of asylum-seekers, provides for a longer period of application (12 weeks, now including appeals), and is subject to more exceptions. In particular, unaccompanied minors can no longer be subjected to it, except where they are ‘national security’ or ‘public order’ risks.

As for appeals in ‘safe country of origin’ cases, it is now the standard rule that they do not have suspensive effect (except for unaccompanied minors in the context of the border procedure), although as before it must be possible for asylum seekers to request suspensive effect from the courts. Some additional safeguards that currently apply to the lack of suspensive effect in border procedure cases have been dropped.

Commission proposal

The Commission’s proposal, dating from April 2025 (see my previous comments here), would first of all allow (as an option) the early application of the revised rules on ‘safe country of origin’, as well as the new ‘20% recognition rate’ rule, in order to provide for the earlier application of the Italy/Albania arrangements; other Member States might have a use for earlier application of the rules too. In fact it would also allow for early application of the partial designation of countries as ‘safe third countries’ too. It will also allow application of the 2024 version of these special rules in the current version of the border procedure (among other things, the 2024 exclusion of most unaccompanied minors from the border procedure will not apply).

Secondly, it would set out a common EU list of ‘safe countries of origin’, as from the entry into force of the Pact: seven named countries (Bangladesh, Colombia, Egypt, India, Kosovo, Morocco and Tunisia) plus candidates for EU accession (Serbia, Montenegro, Albania, North Macedonia, Bosnia-Herzegovina, Turkey, Ukraine, Moldova and Georgia). The accession candidates would be subject to special rules: their listing would switch off if they have been subjected to EU foreign policy sanctions ‘adopted in view of the country’s actions’, or if their recognition rate is above 20% at first instance, or if there is a ‘serious and individual threat to a civilian’s life or person by reason of indiscriminate violence’ in that country (which is one of the grounds for ‘subsidiary protection’ in EU law). It is not certain whether the usual rules on suspending a country from the list also apply to accession candidates, given that a special new category has been created for them. The proposal would list all these countries as a whole, ie not using any of the exceptions for parts of a country or groups of people which the Commission argued were so essential to provide for Member States.

Council position

The recently agreed Council position has taken over most of the Commission proposal. While the Council accepts the early application of parts of the Regulation and the common EU list of ‘safe countries of origin’, including the accession candidate countries (subject to a special rule), it would make a few amendments. (A statement by Hungary objects to having a special rule for accession candidates, preferring to list them automatically without any conditions – although listing them automatically is a special rule in itself)

First of all, the Council position would amend the proposal so that it would be possible to suspend a country partly from a common EU list of ‘safe third country’ or ‘safe country of origin’, on the same basis that Member States can designate a country only partly, ie geographically or as regards groups of people. If a country is partly removed from the common EU list by EU legislation, Member States would not need the Commission’s approval to reinstate that country partly to a national list.  

Secondly, the Council would alter the special conditions applicable to accession countries. The ‘subsidiary protection’ ground for disapplying the status would no longer refer to an ‘individual’ threat, presumably because an assessment is being made of a country as a whole in this context. Also, the foreign policy sanctions ground for disapplying the status would only apply to that country’s actions ‘affecting fundamental rights and freedoms that are relevant for the criteria of designation of a third country as a safe country of origin’ set out in the Regulation. The Council also sets out a procedure for applying these exceptions: the Commission must inform Member States and the Council of the change in status. However, as regards the (quasi-)‘subsidiary protection’ exception, the Commission needs the prior approval of the Council (presumably by qualified majority) before informing Member States of that change. According to the preamble, this is necessary in light ‘of the potential implications for the external relations of the Union and the Member States’ in this scenario.

European Parliament position

The European Parliament’s position (agreed by a committee, and to be reviewed in the full Parliament shortly) is similar to the Council’s. On the first point, the EP agrees that it would, in effect, be possible for countries on the common EU list to be suspended only partly, although it goes into less detail than the Council does.

On the second point, the EP retains the ‘individual’ threat aspect of removing an accession candidate from the common EU ‘safe third country’ list, but also adds that a candidate country should be automatically removed from the list on this ground if the EU’s temporary protection Directive has been applied to that country. This obviously refers solely to Ukraine at present (until March 2027, as things stand). The EP would amend the foreign policy sanctions ground for removal from the list in the same way as the Council.

As for the process, the EP wants the Commission to remove candidate countries from the list by means of a delegated act, rather than by informing the Council and getting the Council’s approval in some cases – although the Council has a role anyway in scrutiny of delegated acts (and in invoking and extending the application of the temporary protection Directive). Using a delegated act – which is, after all, already the usual process set out in the Regulation for suspending a country from the common list – would also give the EP a role in the suspension process.

The EP would also make some amendments to the preamble. One of them, indicating that assessments of the safety of non-EU countries should be ‘accessible’, reflects the Alace judgment. But another amendment to the preamble plainly conflicts with that judgment, purporting that:

…national judicial review should examine the detailed evidence regarding an applicant’s individual situation justifying, in his or her case, the inapplicability of the concept of safe country of origin and not the designation as such.

 

‘Safe third countries’

Current rules

The 2013 rules (again, an option for Member States) provide that a non-EU country can be considered a ‘safe third country’ (the position of EU countries and the associated countries of Switzerland, Norway, Iceland and Liechtenstein is a separate issue) if several criteria are satisfied: no threat to [life or liberty’ on any of the grounds set out in the Refugee Convention; ‘no risk of serious harm’ as defined in EU law as regards subsidiary protection; respect of the non-refoulement principle in the Refugee Convention (ie not sending the asylum seeker to an unsafe country); respect for ‘the prohibition of removal, in violation of the right to freedom from torture and cruel, inhuman or degrading treatment as laid down in international law’; and the possibility ‘to request refugee status and, if found to be a refugee, to receive protection in accordance with’ the Refugee Convention.  

The ‘safe third country’ principle must be ‘subject to rules laid down in national law, including’: rules requiring a ‘connection’ with the other country, ‘on the basis of which it would be reasonable’ for the asylum-seeker to go there; rules on ‘methodology’ concerning the application of the principle to particular countries or applicants; and rules permitting the asylum-seeker to challenge the alleged safety of the country concerned for them, as well as their supposed connection with it.

‘Safe third country’ applications may be considered inadmissible, ie not considered on the merits; but if the supposedly safe country does not permit the person concerned to enter its territory, the Member State must fully consider the merits of their claim. This rule has been confirmed by the Court of Justice, in a case where Greece was breaching it by ruling thousands of claims inadmissible because Turkey was ‘safe’, even though Turkey was no longer readmitting any of the asylum seekers concerned.

A special inadmissibility interview is held, rather than an interview focussed on the well-foundedness of the asylum claim as such. The Directive hints that Member States may have separate time limits for such cases.

As with ‘safe countries of origin’, the ‘safe third country’ rule is another ground to apply a special borders procedure (if Member States opt to do so). Conversely, the suspensive effect of an appeal cannot be denied in ‘safe third country’ cases.

2024 Regulation

The 2024 rules – which remain an option for Member States – are now subject to a definition of ‘effective protection’, in place of an opportunity to request and receive Refugee Convention refugee status: if a non-EU country ‘has ratified and respects’ the Convention, within the limits of any reservations and limitations, that country ‘shall be considered to ensure effective protection’; but if has not ratified the Convention, or applies a geographical limit to it (ie Turkey), that country ‘only’ offers effective protection for people where, ‘as a minimum’, that country allows people to remain, offers subsistence, health care and education, and ‘effective protection remains available until a durable solution can be found’. So even countries which have not ratified the Convention at all can be regarded as offering ‘effective protection’, if they meet these other conditions.

As with ‘safe countries of origin’, it is now possible to regard a country as a ‘safe third country’ only partly, ie ‘with exceptions for specific parts of its territory or clearly identifiable categories of persons’. A country can even be a ‘safe third country’ for an individual applicant. There is a special safeguard for unaccompanied minors:

A third country may only be considered to be a safe third country for an unaccompanied minor where it is not contrary to his or her best interests and where the authorities of Member States have first received from the authorities of the third country in question the assurance that the unaccompanied minor will be taken in charge by those authorities and that he or she will immediately have access to effective protection as defined in [the Regulation].

The law still rules out holding ‘safe third country’ applications to be inadmissible if the other country refuses to admit or readmit the person concerned on to its territory.

There will now be a two-month deadline for deciding ‘safe third country’ applications (and most other inadmissible applications), with a possible extension of up to two months in certain circumstances.

The revised border procedure in the Regulation (described above), also applies to ‘safe third country’ cases. There is also now a new prospect of a common EU list, which works the same way as the possible common list of ‘safe countries of origin’ (and removals from it) described above. Finally, appeals in ‘safe third country’ cases still have automatic suspensive effect.

Commission proposal

The Commission’s proposal, dating from May 2025 (see my previous comments here), would alter the rules as regards the asylum-seeker’s links to the country concerned, so that a ‘connection’ to that country would no longer be the only ground for applying the principle. It could also apply where either the asylum seeker had transited through that country, or a Rwanda-type deal existed with a country that the asylum had neither a connection with nor transited through: ‘there is an agreement or an arrangement with the third country concerned requiring the examination of the merits of the requests for effective protection made by applicants subject to that agreement or arrangement’. However, the latter new criterion would not apply to unaccompanied minors, and in any case there would be an obligation to consider the best interest of the child. Member States would have to inform the Commission and other Member States in advance of concluding such agreements or arrangements.

Secondly, the Commission proposal would alter the rules on appeals, so that there would no longer be automatic suspensive effect in ‘safe third country’ appeals, except for unaccompanied minors subject to the border procedure. Nevertheless, it would be possible to request a court to grant suspensive effect.

The ‘safe third country’ principle would remain optional for Member States, and the Commission does not propose to change the criteria defining the ‘safety’ of a country as such, the applicable deadlines, the related rules on the border procedure, the current safeguard for unaccompanied minors or the requirement that Member States must consider the merits if the third country concerned refuses to admit the asylum seeker. Nor does it propose to use the power to adopt a common EU list of ‘safe third countries’.

Council position

The Council’s position would take on board the Commission’s main points, clarifying that the transit in question must be ‘on the way to the Union’, and providing for the EU, not only Member States, to enter into negotiations with non-EU countries which the asylum seekers have no link at all to. New provisions would require the Commission, when negotiating such agreements or arrangements, to take Member States’ existing agreements or arrangements into account, including the potential impact of EU agreements or arrangements on cooperation of the non-EU countries with certain Member States. But an agreement or arrangements with the EU, once concluded, will take priority over agreements or arrangements with Member States, where they are incompatible.

Member States negotiating such agreements or arrangements must inform other Member States and the Commission of them prior to their entry into force or provisional application, and also inform other Member States and the Commission of any amendments or termination. A notification should come at an (unspecified) earlier point where the agreements or arrangements are with a non-EU country that borders on a Member State (ie Germany sending asylum seekers to Turkey may have a particular impact on Greece). As an option (according to the preamble), Member States could consult the Commission at an earlier stage, with a view to considering the compatibility of the draft agreement or arrangement with EU law. The Council version would also allow for different ways to inform a non-EU country that the applications of asylum-seekers being sent there have not been considered on the merits.

This negotiation position maintains the exclusion of unaccompanied minors from the ‘Rwanda clause’. On the other hand, it would drop the general reference to the rights of the child that the Commission wanted to insert in the main text, although the preamble would retain a reference to this principle, adding that ‘Member States should also take due account of the principle of family unity when applying the safe third country concept’. The safeguard already in the 2024 Regulation for unaccompanied minors, described above, would not be amended by either the Commission or the Council.

The Council’s version would also drop automatic suspensive effect in cases where the asylum seeker has international protection from another Member State. Greece objects to this. It should be noted that the Court of Justice case law provides for the possibility of applying for international protection in another Member State to avoid harsh conditions in the Member State which granted such protection, where the latter Member State treats the beneficiaries of international protection so badly that it amounts to a breach of the EU Charter of Fundamental Rights.

Finally, the Council version tries to clarify some elements of the ‘safe third country’ rule in the preamble. As regards the concept of a ‘connection’ (which will, of course, matter less than it does at present, given the two new categories of ‘safe third countries’):

While taking fully into consideration the parameters outlined in the case law of the Court of Justice of the European Union, Member States should be able to apply the safe third country concept on the basis of a connection as defined in conformity with national law or practice, in so far as specifically defined therein. The connection between the applicant and the third country could be considered established in particular where members of the applicant’s family are present in that country, where the applicant has settled or stayed in that country, or where the applicant has linguistic, cultural or other similar ties with that country.

Transit through a non-EU country is also clarified:

transit through a third country could include the situation where an applicant has passed through, or stayed on, the territory of a third country on the way to the Union, or where the applicant has been at the border or in a transit zone of a third country, where he or she has had the possibility to request effective protection with the authorities of that country

As for the Rwanda-style arrangements, they ‘could include a variety of case-processing modalities, such as simplified, group or prima facie procedures’. This wording seems to imply a potentially dismissive attitude to the non-EU country considering the merits of applications.

European Parliament position

The European Parliament’s position (again agreed by a committee, and to be reviewed in the full Parliament shortly) is similar to the Council’s. In fact, the EP would only make two changes to the main text of the Commission proposal. First, like the Council, the EP would also provide for the possibility of the EU, not only individual Member States, negotiating Rwanda arrangements, although it goes into less detail than the Council version about the mechanics of this. (Its proposed changes to the preamble would, however, require Member States to inform about bilateral talks at an earlier point, and inform the EP too; and the arrangements would have to be in writing).

Second, the EP version would subject unaccompanied minors to the Rwanda clause if there are ‘reasonable grounds’ to believe that they are a security or public order threat ‘under national law’. While the Court of Justice has usually interpreted security exceptions from asylum law narrowly, the reference to national law may be intended to give Member States more leeway. The EP would, however, retain the general reference to the ‘best interests of the child’ being added to the main text.

The EP also suggests changes to the preamble to the proposal, some of which align broadly with the Council’s. On the ‘connection’ with the ‘safe third country’, the EP states that:

The connection between the applicant and the safe third country could be considered established in particular where members of the applicant’s family are present in that country or where the applicant has settled or stayed in that country, or where the applicant has other links with that country, such as the same or similar language, or other economic, cultural, religious, or geographical links.

Unlike the Council’s version, there are, however, no broad references to national law in this context.

The EP version supports automatic suspensive effect being removed from most ‘safe third country’ appeals, although unlike the Council, it would not also remove automatic suspensive effect from appeals made by those who have international protection already from another Member State.

 

Assessment

First and foremost, one of the amendments proposed by the EP would be plainly unlawful, as an obvious breach of the EU Charter of Fundamental Rights. The Court of Justice’s Alace judgment refers several times to Article 47 of the Charter (the right to an effective remedy and a fair trial), when ruling that it must be possible to challenge the designation of countries as ‘safe countries of origin’ (underlining and bold text added):

…it should be noted that the obligation imposed on Member States by Article 46(1) of Directive 2013/32 to provide for a right to an effective judicial remedy for applicants for international protection, the scope of which is defined in Article 46(3) of that directive, corresponds to the right to an effective remedy guaranteed by Article 47 of the Charter… [para 53]

…although, in the absence of EU rules on the matter, it is for the national legal order, in accordance with the principle of procedural autonomy of Member States and subject to the observance of the principles of equivalence and effectiveness, to lay down the detailed procedural rules governing remedies for ensuring that individual rights derived from the EU legal order are safeguarded, Member States nevertheless have the responsibility to ensure observance in every case of the right to effective judicial protection of those rights as guaranteed by Article 47 of the Charter, the scope of that right being clarified, in the present case, by Article 46 of Directive 2013/32… [para 64]

…the choice, by a Member State, of the competent authority and the legal instrument effecting the designation, at national level, of safe countries of origin, in accordance with Articles 36 and 37 of Directive 2013/32, cannot affect its obligations under that directive. It is thus for each Member State, inter alia, to ensure respect for the right to an effective judicial remedy which Article 46(1) of that directive confers on applicants for international protection against decisions taken on their applications, the scope of which is defined by Article 46(3) of that directive. [para 65]

In that regard, the Court has held that, in accordance with Article 46(3) of Directive 2013/32, read in the light of Article 47 of the Charter, where an action is brought before a national court or tribunal against a decision taken on an application for international protection – examined in the context of the special scheme applicable to applications lodged by applicants from third countries designated, in accordance with Article 37 of that directive, as safe countries of origin – that court or tribunal must, as part of the full and ex nunc examination required by Article 46(3) of that directive, raise, on the basis of the information in the file and the information brought to its attention during the proceedings before it, a failure to have regard to the material conditions for such designation, set out in Annex I to that directive… [para 66]

Consequently, and having regard to the case-law referred to in paragraphs 62 and 63 above, the fact that a Member State has chosen to designate safe countries of origin by means of a legislative act cannot be such as to preclude the national court or tribunal seised in the circumstances set out in the preceding paragraph of the present judgment from reviewing, even if only indirectly, whether the designation of the third country in question as a safe country of origin complies with the material conditions for such a designation, set out in Annex I to Directive 2013/32. [para 67]

In the light of the foregoing, the answer to the first questions is that Articles 36 and 37 and Article 46(3) of Directive 2013/32, read in the light of Article 47 of the Charter, must be interpreted as not precluding a Member State from designating third countries as safe countries of origin by means of a legislative act, provided that that designation can be subject to judicial review as regards compliance with the material conditions for such a designation, set out in Annex I to that directive, by any national court or tribunal hearing an action brought against a decision taken on an application for international protection, which had been examined under the special scheme applicable to applications lodged by applicants who are from third countries designated as safe countries of origin. [para 68]

As the Charter has the same legal value as the Treaties (Article 6 TEU), any EU law adopted in breach of it would be invalid.

The EP majority has also not thought this amendment through. It is not reflected in the main text of the Regulation; and it is unclear if the amendment is somehow intended to prevent a review of the validity of a designation on the common EU list too. But Article 267 TFEU provides that a national court can ask the Court of Justice about the validity of EU legislation; if the EP amendment is intended as an attempt to preclude that, then it would be unlawful for a second reason.

Otherwise, as discussed already, there is not must difference between the EP and Council positions on either proposal. Traditionally the EP has taken a significantly more liberal view than the Council on asylum issues, but now the two are broadly in sync (and both in a more restrictive direction than in the past), with the EP even more restrictive than the Council on some points, although the Council is more restrictive than the EP on some points too.

On the ‘safe country of origin’ proposal, the EP’s position on the definitions and process regarding candidate countries is more convincing: it is logical that applying the temporary protection Directive should lead to an automatic exclusion from the common list of ‘safe countries of origin’, and it would make sense to follow the usual delegated acts process for suspending a country from the list, rather than an ad hoc intergovernmental process that only gives a role to the Council (there’s history here: the Court of Justice previously ruled against the Council’s botched attempt at an ad hoc intergovernmental process as regards the very same issue).

As regards the ‘safe third country’ proposal, the Council’s attempt to extend the removal of automatic suspensive effect is an unprincipled reach into another area of EU asylum law, and would in any event remove an essential feature of an effective remedy as regards potential breaches of Charter rights. But the removal of automatic suspensive effective from ‘safe third country’ cases is also problematic, especially in light of the extremely broad definition of the concept that would follow from the proposals.

The introduction of a ‘Rwanda clause’ in EU asylum law undercuts the traditional argument that asylum-seekers ‘should have’ applied in another country. Nevertheless, this rationale even appears in the Council’s press release:

The safe third country concept allows EU member states to reject an asylum application as inadmissible (i.e. without examining its substance) when asylum seekers could have sought and, if eligible, received international protection in a non-EU country that is considered safe for them.

Frankly, this is untruthful. It is not serious to suggest that an asylum-seeker who made their way from Syria, Eritrea or Afghanistan to the European Union ‘could have sought’ international protection in Rwanda, a country many hundreds of miles from any route they would have taken. ‘Could have sought’ is not a rule in the legal text either. Trump-style dishonesty about migration and asylum should not be appearing in the output of the press office of an EU institution.

A Rwanda-clause – unlike the introduction of the transit clause in the ‘safe third country’ definition – has nothing to do with the route the asylum-seeker took, and everything to do with the destination country’s desire to dump the asylum-seeker in any State that will take them. This will inevitably become a key issue as regards the application of the law.

Adding the possibility of the EU asking non-EU countries for Rwanda treaties – as both the EP and the Council would like – does not change the game much. Although the EU has levers at its disposal to use the new transit clause – because its readmission treaties provide that the other parties must take back not only their own citizens, but also non-citizens who transited through their countries, and the EU’s visa code, visa waiver suspension rules, and soon trade policy laws, all sanction countries that do not comply – there are no such levers as regards Rwanda treaties. It remains to be seen what threats and bribes the EU and its Member States are willing to develop, and how easily the Rwandas of the world can be coerced or tempted by them.

 

Friday, 21 November 2025

 



Misreading the Temporary Protection Directive? The CJEU sets the record straight on access to subsidiary protection in Framholm (C-195/25)

 

Dr Meltem Ineli Ciger, Associate Professor of International Law, Suleyman Demirel University

 

Photo credit: Dietmar Rabich, Münster, Stadtweinhaus, Beflaggung Ukraine und EU -- 2022 -- 0219, CC BY-SA 4.0

Framholm (C-195/25), delivered on 20 November 2025, is the Court of Justice’s third ruling interpreting the Temporary Protection Directive (Council Directive 2001/55/EC, TPD) following Joined Cases C‑244/24 and C‑290/24 (Kaduna) (cf. analysis here), and Case C‑753/23 (Krasiliva) (cf. analysis here). The ruling provides further clarification of Articles 3, 17 and 19 of the TPD and, crucially, confirms that temporary protection does not exclude access to subsidiary protection, ie the type of international protection available for those who do not qualify for refugee status. It therefore marks an important step in aligning the TPD, an instrument drafted in 2001, with the contemporary Common European Asylum System (CEAS).

The reference for a preliminary ruling to the Court of Justice originated in Sweden, where several third-country nationals displaced from Ukraine were granted temporary protection and subsequently applied for subsidiary protection. For years, the Swedish Migration Agency (Migrationsverket) had maintained a practice of automatically rejecting subsidiary protection applications lodged by temporary protection beneficiaries, without any examination on the merits. It interpreted Swedish law as allowing temporary protection beneficiaries to apply only for refugee status and treated all subsidiary protection applications as per se inadmissible. Faced with this restrictive and legally questionable approach, the Göteborg Administrative Court for Immigration Matters asked the CJEU whether EU law really permits a Member State to deny access to subsidiary protection solely because the applicant already enjoys temporary protection. The Court’s answer is unequivocal: No.

1.    What is the case about?

 On 11 March 2025, the Göteborg Administrative Court for Immigration Matters referred questions to the CJEU concerning whether beneficiaries of temporary protection may apply for subsidiary protection under the Qualification Directive (or QD – which defines refugee and subsidiary protection status in the EU) and have that application examined on the merits. All applicants (a Nigerian national holding a permanent residence permit in Ukraine and his Ukrainian family members) had been displaced from Ukraine following the Russian invasion and were granted temporary protection in Sweden. When they applied for international protection, the Migration Agency rejected their refugee status applications but declared their subsidiary protection claims inadmissible solely because they already held temporary protection. No assessment of eligibility under Article 15 of the QD (ie the definition of subsidiary protection) was undertaken. The referring court rightly doubted whether such a blanket exclusion could be reconciled with the development of EU asylum law since 2001, which clearly conceptualises “international protection” as including both refugee status and subsidiary protection. (cf. The Judgment paras 28-37)

2.     The questions referred to and the Court’s short answers

The Göteborg Court referred four questions to the CJEU (OJ C/2025/2651, 19 May 2025), all centred on how temporary protection interacts with the CEAS:

1.    Do the QD and the Asylum Procedures Directive 2013/32/EU (APD) apply to international protection applications lodged by persons already benefiting from temporary protection under the TPD? Yes.

2.    a) Does the term “application for asylum” in Articles 17(1) and 19(2) of the TPD cover applications for both refugee status and subsidiary protection, and must such applications be examined under the QD and APD? Yes.
b)
Does Article 3(1) of the TPD prevent Member States from recognising subsidiary protection for persons who are eligible for, or already enjoying, temporary protection? No.

3.    If Articles 17(1) and 19(2) of the TPD also cover the right to apply for subsidiary protection status under the QD, are those articles, in conjunction with Article 10(2) of APD, sufficiently clear and precise to have direct effect?  Yes, and kind of yes (the Court said the QD and APD provisions have direct effect, but did not say that the TPD provisions alone have direct effect)

4.    Is Swedish law, which allows temporary protection beneficiaries to apply only for refugee status (but not subsidiary protection), compatible with EU law? No.

3.    What are Articles 3, 17 and 19 of the TPD about?

Article 3(1) of the TPD makes clear that temporary protection does not prejudge refugee status under the Refugee Convention. It is not a derogation from the Refugee Convention, nor does the grant or expiry of temporary protection affect the substantive assessment of whether an applicant meets the refugee definition.  

Article 17 of the TPD guarantees that beneficiaries of temporary protection may lodge an asylum application at any time and provides that any applications still pending when temporary protection ends must be assessed and decided hereafter.

Article 19 of the TPD regulates the interaction between temporary protection and the asylum procedure: Article 19(1) allows Member States to decide that a person cannot simultaneously hold the status of “asylum seeker” and benefit from temporary protection while their asylum application is being examined. Whereas Article 19(2) ensures continuity of protection: if, after examining an asylum application, the authorities do not grant refugee status or another form of protection, the person must still be allowed to enjoy temporary protection for the rest of the designated duration. (Cf. for a detailed commentary on these articles Skordas’ chapter; Peers’ post; Ch. 5 of my book)

4.    The AG Opinion (which I fully agree with)

The Advocate General’s analysis is worth examining closely, not least because it is carefully constructed and has clear implications for how the TPD must be read today. His reasoning develops along five points.

First, AG interprets Article 17(1) TPD’s reference to an “application for asylum” as an application for international protection, encompassing both refugee status and subsidiary protection. Although the TPD predates the CEAS, it must now be read in light of Article 78(2) TFEU, which is a Treaty provision on asylum (AG Opinion, paras 49-58). He adds “A restrictive understanding of the term ‘asylum’ in Article 17(1) of Directive 2001/55 would fail to take into account the context in which that directive applies following the entry into force of the FEU Treaty, as well as the objectives and scope of the legislation concerning ‘international protection’ which has been adopted in the intervening period.”  (para 50)  

Secondly, the AG stresses that temporary protection does not suspend or exclude access to subsidiary protection. Beneficiaries of temporary protection may lodge applications for refugee or subsidiary protection “at any time,” and the TPD operates as a complement, not an alternative, to the individual assessment required under the Qualification Directive (AG Opinion, paras 43-45, 51-52, 59-61, 66).

Thirdly, he confirms that being a temporary protection beneficiary is not a lawful ground of inadmissibility or exclusion. The exhaustive lists in Articles 12 and 17 of the QD (on grounds for excluding people from refugee or subsidiary protection status) and Article 33(2) APD (grounds for inadmissibility of asylum applications) do not include temporary protection, and national authorities cannot refuse subsidiary protection applications on that basis (AG Opinion, paras 70-72, 78-81).

Fourthly, he accepts that Member States may postpone examination of international protection applications in mass influx situations but makes clear that this administrative flexibility cannot justify a blanket inadmissibility rule for all subsidiary protection applications lodged by temporary protection beneficiaries (AG Opinion, paras 73-80, especially 7-78, 86).

Finally, he concludes that Article 17(1) TPD (not Article 19), read together with the overall CEAS architecture, confers a sufficiently clear and directly effective right to lodge an application for international protection.  

5.    What did the Court say?

The Court’s reasoning proceeds in three clear steps.

First, the Court explains that nothing in Articles 3, 17 or 19 TPD authorises Member States to refuse to examine a subsidiary protection claim simply because the applicant enjoys temporary protection (paras 45-46). Article 19(2) even anticipates the existence of “other kinds of protection,” which must be read today as encompassing subsidiary protection (para 46). The omission of subsidiary protection in the TPD text reflects only the fact that this status did not yet exist in EU law, a point that AG raised. (paras 46-47).

Secondly, the Court turns to the purpose and logic of the TPD. Temporary protection is designed to ensure immediate, time-limited protection while preserving the “effective possibility” of receiving international protection (paras 47–49). Here the Court explicitly follows its reasoning in Joined Cases C‑244/24 and C‑290/24 (Kaduna), where it held that “the purpose of the temporary protection mechanism is, inter alia, to maintain the efficient operation of the international protection system in the Member States” and that the TPD “safeguards, in particular, the effective possibility for third-country nationals and stateless persons benefiting from temporary protection" of obtaining international protection following an appropriate examination of their individual situation” (Kaduna, paras 125 and 127). A national rule excluding subsidiary protection applications as such would therefore contradict the very objective of the TPD (paras 49–50).

Thirdly, and most decisively, the Court relies on the architecture of the CEAS. It emphasises that the QD establishes two forms of international protection – namely, refugee status and subsidiary protection – and that Member States must grant whichever status an applicant qualifies for (paras 51–54). Member States have no discretion to refuse subsidiary protection except on the exclusion grounds exhaustively listed in the Qualification Directive (para 54). The Asylum Procedures Directive reinforces this: an application may be declared inadmissible only on the five grounds set out in Article 33(2) APD, which must be interpreted strictly (paras 58–60). Temporary protection is not among these grounds; national authorities, therefore, cannot reject a subsidiary protection application solely because the applicant enjoys temporary protection (para 61).

Finally, the Court addresses the direct-effect question. The Swedish court had essentially asked whether Articles 17(1) and 19(2) of the TPD, if interpreted as including the right to apply for subsidiary protection, are sufficiently clear and precise, read together with Article 10(2) of the APD, to have direct effect. The CJEU reformulates the issue. Rather than grounding the direct effect in the TPD itself, the Court bases it on two CEAS provisions: Article 18 of the QD, which imposes an unconditional duty to grant subsidiary protection when criteria are met, and Article 33 of the APD, which exhaustively lists the admissibility grounds (paras 71-72). These provisions are both unconditional and sufficiently precise, and thus confer directly effective rights. The consequence is clear: if a national rule conflicts with these obligations and cannot be interpreted in conformity with EU law, domestic courts must disapply the national provision (para 73).

That said, the Court’s approach leaves an important ambiguity unresolved. The referring court had explicitly asked whether Articles 17(1) and 19(2) of the TPD, read together with Article 10(2) APD (which governs the relationship between refugee and subsidiary protection status applications), were sufficiently clear and precise to have direct effect. Instead of answering that question squarely, the Court effectively sidesteps it by grounding direct effect not in the TPD at all, but in Article 18 QD and Article 33 APD. Put simply, the judgment does not tell us whether Articles 17(1) and 19(2) of the TPD are capable of producing direct effect. 

6.    My analysis

The AG’s Opinion and the Court’s judgment reach the same legal outcome, but they do so through markedly different interpretative routes. The Advocate General adopts a more TPD-centred approach, grounding his analysis in Articles 3, 17 and 19 of the TPD and then interpreting these provisions in light of later CEAS instruments. He reads “asylum application” in Article 17 as an application for international protection covering both refugee status and subsidiary protection, emphasises that temporary protection cannot suspend or exclude access to subsidiary protection, and rejects temporary protection as a lawful ground of inadmissibility because it does not appear in the exhaustive list in Article 33(2) of the APD. Although he accepts that Member States may postpone international protection application examinations in mass influx situations, he stresses that a blanket ban on subsidiary protection applications is incompatible with the TPD and the CEAS.

By contrast, the Court relies primarily on the Qualification Directive and the Asylum Procedures Directive, using the CEAS instruments themselves as the main foundation for each key step. It interprets “asylum application” in light of the QD and APD definitions of international protection, derives the duty to grant protection from Article 18 of the QD and the obligation to examine claims (and the limits on inadmissibility) from Articles 10(2) and 33 APD, and treats Article 33(2) of the APD as an exhaustive rule that excludes any TP-based inadmissibility ground (paras 58-60). On the direct effect, the Court bases its analysis on Article 18 of the QD and Article 33 of the APD (paras 70-73), whereas the AG reaches the same conclusion via a combined reading of Article 17 of the TPD with the CEAS provisions.

Compared to the AG’s Opinion, which engages more directly with the wording, structure and logic of the TPD, the Court reaches essentially the same conclusions but grounds its reasoning far more firmly in the QD and APD. Put differently, while the AG reads the TPD through the lens of the CEAS, the Court treats the CEAS instruments themselves as the primary legal basis for explaining why Member States cannot refuse to examine (and, where appropriate, must grant) subsidiary protection to temporary protection beneficiaries.

I must admit that I prefer the AG’s TPD-centred approach: it is more faithful to the architecture of the TPD, and does not treat the TPD as a second-rate asylum instrument because it has never been updated to reflect two decades of CEAS development.

The outcome of the judgment is fully in line with what many of us working on the TPD have long expected. The TPD was never intended to operate as an obstacle to accessing international protection, whether refugee status or subsidiary protection. For over a decade, “international protection” in EU law has included both statuses, and nothing in the Directive suggested a closed or self-standing regime intended to override the CEAS.

The central logic of the TPD has always been pragmatic: to give Member States facing a mass influx breathing space by allowing them to suspend the processing (not lodging) of asylum claims where their systems would otherwise be overwhelmed. It was and never has been designed to bar access to subsidiary protection altogether. Member States with fewer temporary protection beneficiaries, or with sufficiently strong asylum systems, remain entirely free to process claims during temporary protection and examine the merits of their international protection applications.

Interpreting the TPD in the restrictive and literal manner adopted by the Swedish administration, treating “asylum” in the TPD as excluding subsidiary protection and ignoring the subsequent development of EU asylum law, was therefore misguided. It runs counter to the TPD’s objectives, its underlying logic, and the entire evolution of the CEAS. Most importantly, it results in a clear violation of the rights of temporary protection beneficiaries to access international protection.

This judgment matters well beyond Sweden. Even if Sweden appears to be the only Member State to have openly applied such a blanket rule, Framholm makes clear that no Member State may treat temporary protection alone as a ground for declaring subsidiary protection applications inadmissible. Across the EU, temporary protection can never justify a blanket refusal to examine the merits of a subsidiary protection claim.

7.    Conclusion

Framholm matters because it definitively closes the door on any national attempt to use temporary protection as a barrier to subsidiary protection. The judgment also exposes a broader structural problem: the Temporary Protection Directive, drafted in 2001, simply do not reflect the legal architecture of the CEAS in 2025. This is visible not only in Sweden’s misinterpretation but also in the Court’s need to rely so heavily on the QD and APD to reach a decision rather than the TPD’s own articles.

This brings me to a point that, as far as I am aware, no one else has explicitly raised: we know that the TPD remains useful and conceptually sound as a framework for managing mass influx situations, contrary to the Commission’s initial 2020 proposal to repeal it. Temporary protection works. It has proven its value during the Ukrainian displacement and remains a necessary instrument in the EU’s protection toolbox. Even today, 4.3 million non-EU citizens who fled Ukraine have temporary protection status in the EU. Moreover, the adoption of the Crisis and Force Majeure Regulation does not render the TPD unnecessary or obsolete: the two instruments, although they can be invoked in exceptional mass influx situations, operate on different logics. In my opinion, the Crisis and Force Majeure Regulation, which is based on derogations more than anything, cannot fully substitute for the protection mechanism established by the TPD.

Despite the usefulness of the ongoing relevance of the TPD, the judgment also implicitly makes clear that the TPD urgently requires updating. Many of the problematic national practices stem precisely from the fact, highlighted by the AG, that the TPD is an old instrument, never recast and never aligned with two decades of CEAS development. The result is predictable: legal ambiguities that should no longer exist, and litigation over issues that should be obvious.

I wish to conclude with a call to the EU institutions, above all, to the Commission. Once the current temporary protection regime for Ukrainians comes to an end, the Commission should initiate a targeted revision of the TPD, drawing directly on the lessons of its implementation during the mass displacement from Ukraine and the emerging body of CJEU case law, including Kaduna, Krasiliva and Framholm. An updated TPD can significantly narrow the scope for misinterpretation, perhaps introduce a new and clear time limit, align the instrument with the contemporary CEAS architecture, and prevent further unnecessary litigation on matters that ought already to be legally settled.