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
Date: 2025-06-11
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU Member State, EU migration policy, activity report, external border of the EU, foreign national, integration of migrants, international protection, migration control, return migration, right of asylum

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   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}  
 
 
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). 

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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.   

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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.  

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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.  

the  Commission  supports 

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 
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.  

ten  Member  States 

the  TSI  on 

through 

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. 

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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. 

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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. 

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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. 

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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. 

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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. 

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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.  

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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. 

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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. 

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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 
the  fair  sharing  of 
Asylum  and  Migration  Management  Regulation  (AMMR),  on 
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. 

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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. 

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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. 

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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. 

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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.  

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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. 

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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, 

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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. 

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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.  

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