​Investigating alleged ill-treatment at the European Unions' external borders : 2025 update.
Date: 2025-08-06
Institutions: European Union Agency for Fundamental Rights
Subjects: EU Member State, EU migration policy, aid to refugees, border control, fundamental rights, human rights, migration control, refugee, report, right of asylum, violence

Contents

Key findings
Introduction
1. National judicial investigations
2. National disciplinary investigations
3. Investigations by Frontex
4. The European Court of Human Rights
Conclusion
Annex: Data on national investigations of alleged ill-treatment at borders

Judicial investigations
Disciplinary investigations

Endnotes
About this publication

2/20

Key findings

For years, human rights actors have been reporting serious, recurrent and widespread rights
violations against migrants and refugees during border management.

In July 2024, the European Union Agency for Fundamental Rights (FRA) identified systemic
gaps in investigating such allegations. Few cases of ill-treatment and other serious
allegations of rights violations were investigated, and when they were, they were closed at
the pre-trial stage. The Agency published the Guidance 
at borders
also called for more transparency in investigations.

on investigating alleged ill-treatment
, which suggests concrete steps to promote effective national investigations. FRA

A year later, FRA has not observed any structural changes aimed at improving the
effectiveness of national investigations of ill-treatment allegations at borders.

On a positive note, more incidents of loss of life and alleged ill-treatment during border
management are being brought to the attention of judicial authorities. Between 2020 and
2024, 12 Member States at the EU’s external land or sea border opened at least 135 criminal
investigations. Judicial authorities in Greece and Italy pressed charges in relation to the
deadly shipwreck incidents in Pylos (June 2023) and Cutro (February 2023).

At the same time, most cases continue to be archived at the pre-trial stage. The number of
convictions remains low, compared to the widespread reports of rights violations. From
2020 to 2024, there were a total of four convictions: three in Hungary and one in Spain.

From 2020 to 2024, at least 161 cases were subject to disciplinary investigations. Out of
these closed cases, 13 led to sanctions: seven in Croatia and six in Hungary.

The European Border and Coast Guard Agency (Frontex) reviews more complaints and
serious incidents involving alleged fundamental rights violations in their area of operation,
recommending preventive and protective measures for Frontex operations. These
procedures do not replace national investigations to restore justice for the victims.
However, national authorities often fail to follow up with effective national investigations
when Frontex concludes that fundamental rights violations have occurred.

The European Court of Human Rights (ECtHR) continues to play an important role in
providing victims with access to justice. In the last four years, it issued six judgments in
which it found that national investigations into migrants’ rights violations at borders were
ineffective. As at 1 July 2025, some 30 cases were pending before the ECtHR in Strasbourg.

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Introduction

Article 47 of the Charter of Fundamental Rights of the European Union provides that
everyone whose rights and freedoms guaranteed by EU law are violated has the right to an
effective remedy before a tribunal. The way Member States organise and run their justice
systems is primarily a matter of national law. EU law relies on functioning national justice
systems.

National investigations must be prompt and effective, respecting the requirements set out
by the ECtHR. The 
Guide on the case-law of the European Convention on Human Rights –
Immigration
 describes the requirements flowing from the European Convention on Human
Rights (ECHR). There is no specific case-law by the Court of Justice of the European Union
on investigations of fundamental rights violations at EU borders.

on investigating alleged ill-treatment at borders
In July 2024, FRA published the Guidance 
The Agency analysed criminal and disciplinary investigations into incidents of loss of life
and alleged ill-treatment that occurred during border management at the EU’s external
borders between 2020 and 2023. The publication covered allegations of failure to rescue
people in distress, physical ill-treatment and other forms of inhuman and degrading
treatment that puts migrants’ life and physical integrity at risk.

.

FRA concluded that national investigations need to be more effective and called for more
transparency on the number of cases investigated and on their results. Ineffective judicial
protection against widespread rights violations poses a risk to the respect of the rule of law
as enshrined in Article 2 of the Treaty on European Union  [1] .

As a follow up to its 2024 publication, in the spring of 2025, with the support of its national
liaison officers
, FRA requested the 16 Member States at the EU’s external borders to update
the information on pending and closed judicial and disciplinary investigations, covering the
period until 31 December 2024. The data collection covered Bulgaria, Croatia, Cyprus,
Estonia, Finland, France, Greece, Hungary, Italy, Latvia, Lithuania, Malta, Poland, Romania,
Slovakia and Spain. FRA received replies from courts, public prosecutors or responsible
ministries and law enforcement bodies in 12 Member States in total (nine Member States
provided updates on judicial proceedings and 10 on disciplinary procedures). In Member
States where FRA did not receive information from the competent authorities, it requested
input from legal actors.

With this publication, FRA provides an update on the state of play of investigations of
alleged ill-treatment at borders up to the end of 2024, covering both judicial and disciplinary
investigations. In addition, this update reflects developments related to Frontex and the
ECtHR.

4/20

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. National judicial investigations

Many Member States do not collect disaggregated data on judicial investigations of alleged
ill-treatment at borders. Therefore, in selected Member States where the Agency was aware
of cases under investigation, FRA contacted also lawyers, civil society representatives and
human rights institutions. The Agency also received information on judicial investigations
by law enforcement authorities and ministries. For these reasons, the data that FRA
collected is neither comprehensive nor comparable across Member States.

The main updates are the following.

Although victims rarely report ill-treatment incidents to the competent authorities   [2] ,
more cases are being brought to the attention of prosecutors.
Between January 2020 and December 2024, at least 135 criminal investigations were
initiated in 12 Member States.
Judicial authorities in Greece and Italy pressed charges in relation to the deadly
shipwreck incidents in Pylos (June 2023) and Cutro (February 2023).
Approximately half of the investigations were initiated in Greece.
Many allegations concern excessive use of force, ill-treatment and theft. In six Member
States, there were allegations of homicide. In two Member States, there were
allegations of rape.
Most cases continue to be closed at the pre-trial stage without the pressing of charges.
The number of convictions remains low. Among the cases closed, there were four
convictions: three in Hungary and one in Spain.

2

 lists the pending and closed criminal investigations of alleged ill-treatment at EU

Table 
borders between 1 January 2020 and 31 December 2024. Cases in which the judicial
authority found no evidence to start an investigation are not included in the table.

In Latvia, for example, the Internal Security Bureau, which conducts criminal investigations
following a complaint, reported to FRA that they reviewed 31 cases. In 19 of them a decision
was taken not to initiate criminal proceedings. One case was referred to the public
prosecutor and criminal proceedings were initiated. Three cases are still open. Some cases
were referred to other bodies, for others the Bureau sent a written reply to the complainant .

Since the previous round of data collection in 2023, a new conviction has been recorded in
Hungary concerning physical assault. According to data provided by the Hungarian police,
one official was sentenced to one year imprisonment (suspended for three years) and fines
were imposed on two other officials  [3] .

In Greece, the Deputy Prosecutor of the Piraeus Naval Court pressed charges against 17
members of the Hellenic Coastguard in relation to the shipwreck off the coast of Pylos,
which resulted in the death of at least 82 persons and left several hundred others missing
(see FRA’s report Preventing 
and responding to deaths at sea – What the European Union
can do

). The charges include  [4] :

1.  causing a shipwreck,
2.  dangerous interference with maritime transport,
3.  failure to provide assistance,
4.  and exposure to danger.

The Greek Ombudsman, in its capacity as the National Mechanism for the Investigation of
Arbitrary Incidents, had concluded an own-initiative investigation that found serious and

5/20

 
 
 
 
 
 
 
 
 
 
reprehensible omissions by the Hellenic Coastguard  [5] . The Ministry of Maritime Affairs
and Insular Policy accused the Ombudsman of drawing arbitrary conclusions and acting
with political motivation  [6] . The Greek National Commission for Human Rights expressed
deep concern, noting that the Ministry’s statement undermined the independence and role
of the Ombudsman  [7] .

In Italy, six officers from the coastguard and the financial police were charged with
negligent shipwreck and multiple manslaughter in relation to the Cutro shipwreck, which
claimed the lives of at least 94 people, including 35 children, off the coast of Cutro, Calabria,
in February 2023  [8] .

Few indictments were also issued in other Member States, such as Poland, mainly for
causing injuries and harming the health of migrants  [9] .

During the past year, FRA did not observe any structural changes aimed at improving the
effectiveness of national investigations. In 2024, FRA commended Poland’s decision to
assign all such investigations to a dedicated team of prosecutors in Siedlce (Lublin
Voivodship)  [10] . However, FRA has not received any update that would enable the Agency
to assess the effectiveness of this initiative.

6/20

 
2. National disciplinary investigations

The objectives and scope of disciplinary investigations vary among Member States. Their
primary aim is to sanction officers’ inappropriate conduct and protect the reputation of law
enforcement actors. They do not necessarily intend to restore justice for the victim.

Out of the 16 Member States contacted by FRA, law enforcement bodies or ministries in
charge of disciplinary investigations in 10 provided data for the 2025 update. Estonia and
Spain had submitted information in 2023 but did not do so for the most recent reporting
cycle.

Table 3 provides an overview of disciplinary investigations opened before the end of 2024.
For Member States that did not reply, FRA included cases reported by other sources.

Some of the cases included in Table 3 have been subject to both disciplinary and criminal
investigations as the authorities in charge of disciplinary investigations forwarded cases
with sufficient evidence of alleged criminal conduct to the public prosecutor.

The main updates on disciplinary investigations are the following.

Between January 2020 and December 2024, at least 161 cases in 11 Member States
were subject to disciplinary investigations.
The most common accusations concern various forms of ill-treatment and theft. There
have also been some allegations of homicide and rape.
Out of the cases closed between 2020 and 2024, 13 led to sanctions: seven in Croatia
and six in Hungary. There have been five new cases of sanctions since FRA’s previous
round of data collection.

The disciplinary sanctions imposed in Croatia included termination of service, along with
conditional or suspended termination of service and fines. The breaches of conduct
concerned police brutality and illegal confiscation of assets  [11] .

The sanctions in Hungary consisted of demotion to a lower grade, termination of service,
reprimands and a delay in promotion for two years. The breaches of conduct in most cases
concerned assault and abuse  [12] .

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3. Investigations by Frontex

Under Article 111 of Regulation (EU) 2019/1896 on the European Border and Coast Guard, a
person whose fundamental rights are directly affected by the conduct of staff involved in
Frontex operational activities may submit a written complaint to Frontex. In July 2025, the
Frontex fundamental rights officer – who handles such complaints – shared the following
data with FRA: from 2016 to 2024, Frontex received 313 complaints, 43 of which were found
admissible. Most complaints (84) were filed in 2024, showing an increase compared to the
64 complaints submitted in 2023.

Most complaints are inadmissible since they concern the conduct of national authorities.
The planned revision of the rules governing the handling of complaints envisage reinforcing
referrals of inadmissible complaints to national complaint handling bodies, subject to the
applicant’s agreement. The upcoming revision of Regulation (EU) 2019/1896 could
introduce, more formally, such a referral mechanism, combined with a duty to inform
Frontex and its fundamental rights officer of the outcome of national investigations.

In 2024, the Frontex fundamental rights officer reviewed the substance of eight complaints
concerning alleged collective expulsions and ill-treatment of migrants: six from Greece to
Türkiye and two from Bulgaria to Türkiye. He recommended to the national authorities that
they reinforce preventive measures and strengthen national investigations  [13] .

Every participant in Frontex operational activities needs to report any situation of potential
violation of fundamental rights through a ‘serious incident report’  [14] . From 2019 to 2024,
the Frontex fundamental rights officer handled 262 serious incident reports, 56 of them in
2024, according to the data he shared with FRA in July 2025.

In 2024, the fundamental rights officer closed 48 serious incident reports finding that in
three out of four cases (37), a fundamental rights violation either occurred or likely
occurred. Only one incident concerned a violation by Frontex. In all other cases, national
authorities were responsible for the confirmed or alleged violation, which in many cases
entailed inhuman or degrading treatment at borders  [15] .

Serious incident reports aim to establish whether fundamental rights violations occurred
and, if so, to recommend mitigating steps for the future. They do not replace criminal or
disciplinary investigations. The Frontex fundamental rights officer noted that national
authorities often fail to follow up on cases where allegations of fundamental rights
violations by their officers are reported  [16] .

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4. The European Court of Human Rights

When domestic remedies are ineffective or have been exhausted without tangible results,
cases are filed with the ECtHR. As shown in Table 1, by 1 July 2025, the ECtHR had
communicated some 30 pending cases entailing alleged ill-treatment at the EU’s external
borders to eight different Member States.

Applicants in these cases allege violence and ill-treatment during apprehension and
subsequent summary return by land to the neighbouring country; ill-treatment during
summary expulsion at sea; delayed search and rescue; abandonment of people in forest
areas at borders without access to basic amenities or exposing applicants to life-
threatening situations; and lack of access to legal remedy to challenge their return.

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Table 1 – ECtHR, communicated cases alleging violations of Articles 2 and 3 of the ECHR, as at
1 July 2025

Member
State

Bulgaria

Croatia

Cyprus

Number
of
pending
cases

1

2

2

Reference

E.R.A.  

v.  Bulgaria

, No 55918/22

S.B.​ 

v.​ Croatia​

, Nos 18810/19, 18865/19 and 23495/19; 
, No 38776/21

Croatia

Y.K.​ v.​

K.P.O.​ 
Nos 32295/24 and 5455/25; 

and​ Others​ v.​ Cyprus​ and​ E.A.A.E.​ and​ Others​ v.​ Cyprus​
,
Kamakwili and Kalonbo v. Cyprus
,

No 36786/24

Wasim​ 

Abonahi​ v.​ Greece​

, No 22920/16; 

N.A.A.​ and​ Others​ v.​ Greece​

and North Macedonia

, No 28795/16; 

A.A.N.​ and​ Other​ v.​ Greece​

, No 38203/20; 

G.K. v. Greece

, No 51519/19;
N.Y.​ and​ Others​ v.​ Greece​
,

Greece

8

No 40725/20; 
Nos 12237/20 and 12736/20; 

L.A.​ and​ Others​ v.​ Greece​ and​ A.A.​ v.​ Greece​
,
S.A.A​ and​ Others​ v.​ Greece​
,

No 22146/21; 

K.A. and Others v. Greece and Turkey, and B.A. and

Others v. Greece and Turkey

, Nos 35090/22 and 38444/22

H.M.M.​ 

and​ Others​ v.​ Latvia​

, No 42165/21, (relinquishment in favour

Latvia

3

of the Grand Chamber of the ECtHR); 

S.S.​ v.​ Latvia​

, No 15408/23;

M.A. 

and Others v. Latvia

, No 1134/23

C.O.C.G.​ 

v.​ Lithuania​

, No 17764/22 (relinquishment in favour of the

Lithuania

2

Grand Chamber of the ECtHR); A.S​ 
No 44205/21

and​ Others​ v.​ Lithuania​

,

R.A.​ 

and​ Others​ v.​ Poland​

, No 42120/21, (relinquishment in favour of

the Grand Chamber of the ECtHR); 
Others v. Poland

K.A. v. Poland and M.A. and
F.A. and S.H. v.

, Nos 52405/21 and 53402/21; 

, No 54862/21; H. 

Poland
and​ Others​ v.​ Poland​
15318/22, 2509/22; 
Nos 15182/22 and 40833/22; 

K. and Others v. Poland

A.A.
, Nos 48018/21, 61103/21, 53181/21, 51241/22,
A.A. and Others v. Poland

, No 12752/22; 

A.S.​ v.​ Poland​

 and M.A. 
, No 15318/22;

,
v. Poland
I.A.​ and​
,

Others v. Poland

, No 53181/21; 

M.M. and Others v. Poland

No 2509/22; 

A.M.​ v.​ Poland​

, No 33674/22

Poland

10

Total

30

NB: The table does not include cases alleging violations of Articles 2 or 3 of the ECHR upon
return to a non-EU country.

Source: FRA (2025) based on  hudoc.echr.coe.int.

Since November 2021, the ECtHR has issued six judgments in which it found that national
investigations into migrants’ rights violations at borders were ineffective or domestic
remedies were not available  [17] . They concerned allegations of violations of the right to life
(Article 2 of the ECHR) and allegations of torture or inhuman or degrading treatment
(Article 3 of the ECHR) during apprehension and subsequent summary return.

10/20

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
v.  Greece

, the ECtHR ruled that authorities failed to initiate prompt, thorough and

In A.R.E.  
independent inquiries, neglecting to collect and to assess crucial evidence or to interview
victims and witnesses, in what has been labelled as a ‘preliminary investigation manifestly
insufficient’ (paragraph 199).

11/20

 
Conclusion

on investigating alleged ill-treatment at borders

FRA’s Guidance 
promote effective national investigations, including ways to enhance their transparency, to
ensure full impartiality and independence of the investigating body from the body involved in
the incident and to allow victims’ participation or secure evidence.

 suggests concrete steps to

The implementation of the pact on migration and asylum offers an opportunity to address
ineffective judicial protection. Article 10 of Regulation (EU) 2024/1356 introducing the
screening of third-country nationals at the external borders expressly obliges Member
States to adopt relevant provisions to investigate allegations of non-respect for
fundamental rights in relation to the screening. Member States must ensure, where
appropriate, referral for the initiation of civil or criminal justice proceedings in cases of
failure to respect or to enforce fundamental rights, in accordance with national law.

Although this provision concerns alleged violations that emerge during the fundamental
rights monitoring of the screening, it is likely that monitors will be confronted with
information and evidence of incidents that concern migrants’ apprehension or their rescue
at sea. When setting up their national mechanisms to monitor fundamental rights under the
pact on migration and asylum, Member States should ensure that designated monitoring
bodies are allowed to trigger investigations and to monitor their progress, also when they
concern events reported during their monitoring of the screening, but which occurred prior
to the screening itself. The European Commission should remain vigilant to this.

12/20

 
 
 
 
 
Annex: Data on national investigations of alleged ill-

treatment at borders

Judicial investigations

The following table lists the pending and closed national criminal investigations of alleged
ill-treatment at borders between 1 January 2020 and 31 December 2024. Cases in which the
judicial authority found no evidence to start an investigation are not included in the table.

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Table 2 – 

Judicial investigations opened in 16 Member States from 2020 to 2024

Member
State

Reply by
judicial
authority

Other replies

Number
of
cases

Number of
convictions

Alleged
conduct
(selected)

Bulgaria

√

civil society

4

0

Croatia

(in 2023)

Ministry of the Interior; civil
society

18

0

excessive use
of force and
theft during
apprehension
and summary
removal to
Türkiye

torture;
inhuman or
degrading
treatment;
rape; robbery;
unlawful
deprivation of
liberty; abuse
of position of
authority

Cyprus

Estonia

Finland

√

√

√

UNHCR and civil society

—

—

0

0

0

0

0

0

—

—

—

France

x

civil society

6

0

Greece

x

Reply of the Greek
authorities to the Council of
Europe Commissioner for
Human Rights; Hellenic
Police; Hellenic Coastguard;
National Human Rights
Commission

68

0

manslaughter
and non-
assistance to
people in
danger
(drowning in
the English
Channel); ill-
treatment and
abandonment
of people
unable to
protect
themselves

ill-treatment;
physical
injury; torture;
rape; theft;
homicide;
illegal use of
firearms

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Member
State

Reply by
judicial
authority

Other replies

Number
of
cases

Number of
convictions

Alleged
conduct
(selected)

Italy

√

legal actors

Latvia

√

Internal Security Office

Lithuania

√

civil society

Malta

x

civil society

Poland

x

civil society; border guards;
police

Romania

√

border police

Slovakia (in 2023)

—

Spain

x

Ministry of the Interior; civil
society and open sources

1

2

2

1

5

3

0

4

0

0

0

0

0

0

0

1

negligent
shipwreck;
multiple
negligent
manslaughter

unlawful
confiscation
of property

severe health
impairment;
abuse of
authority

wilful
homicide and
attempted
wilful
homicide
(delayed
rescue)

causing
damage to
health;
unintentional
manslaughter

abusive
behaviour and
theft

—

homicide by
gross
negligence;
denial of
assistance;
beating
causing loss
of vision;
excessive use
of force

Total

135

4

NB: The table includes only cases that FRA could identify and is therefore not
comprehensive. FRA did not receive any new information for Malta, Slovakia and Spain. For
Italy, FRA received a reply by its national liaison officer. For Croatia, some cases may have

15/20

 
 
 
been counted twice, as FRA could not verify whether cases reported by the authorities and
by civil society were the same. For Lithuania, FRA reassessed a 2022 case that was not
covered in FRA’s 2024 report and included it in this update.

√ = FRA received information from prosecutorial or judicial authorities
x = FRA did not receive information from prosecutorial or judicial authorities
UNHCR = Office of the United Nations High Commissioner for Refugees

Source: FRA (2025), based on an exchange of information with prosecutorial or judicial
authorities or publicly available sources

Disciplinary investigations

The following table provides an overview of national disciplinary investigations opened
before the end of 2024. For Member States that did not reply, FRA included cases reported
by other sources.

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Table 3 – Disciplinary investigations opened in 16 Member States from 2020 to 2024

Member
State

Bulgaria

Croatia

Cyprus

Estonia

Finland

France

Greece

Hungary

Italy

Latvia

Lithuania

Malta

Poland

Romania

Slovakia

Spain

Total

Reply
to FRA
request

Number
of
reported
cases

Number of
cases in which
sanctions were
imposed

Alleged conduct (selected)

x

√

√

(in
2023)

√

x

√

√

x

√

√

x

√

√

√

(in
2023)

1 (*)

20

0

0

1

11 (*)

81

20

n/a

3

4

n/a

violent pushback

7

0

0

0

0

0

6

n/a

0

0

police brutality; illegal confiscation of
assets

—

—

pressure and threats in order to provide
information

deliberate violence; exposure to risk of
death or injury; insulting language

ill-treatment, torture, rape and theft
during apprehension and summary
removal to Türkiye; homicide; illegal use
of firearms

abuse; use of dogs against migrants

—

—

unnecessary use of coercive measures;
discrimination; abuse of power

n/a

n/a

—

harassment; misappropriation of
personal belongings; causing damage to
the health of migrants; unintentional
manslaughter

abusive behaviour; physical aggression;
theft

—

physical injuries; assault

0

0

0

0

13

5

0

2

161

13

NB: FRA did not receive any new information from Bulgaria, Estonia, France, Italy, Malta and
Spain.(*) = The cases were reported for FRA’s 2024 report by FRA’s multidisciplinary
research network FRANET after consultations with national human rights bodies,
organisations providing support or legal aid to refugees and migrants, and lawyers.

17/20

 
 
Source: FRA (2025), based on an exchange of information with enforcement bodies and
ministries in charge of disciplinary investigations.

18/20

Endnotes

[1]  FRA, Submission by the European Union Agency for Fundamental Rights to the European Commission in
the context of the preparation of the annual Rule of Law Report 2023, Vienna, 2023, p. 42. 

[2]  FRA, Guidance on investigating alleged ill-treatment at borders, 30 July 2024, pp. 11–12. 

[3] Information provided by the Hungarian police in April 2025. 

[4]  Network of Social Support for Refugees and Migrants, Hellenic League for Human Rights, Greek Council
for Refugees, Initiative of Lawyers and Jurists for the shipwreck of Pylos, Refugee Support Aegean et al. –
Press release, ‘Pylos Shipwreck: Criminal prosecution for felonies against 17 members of the Coast Guard,
including senior officers of its leadership’, 23 May 2025. 

[5]  Greek Ombudsman – Press release, ‘Findings of the Greek Ombudsman in relation to the Pylos
shipwreck’, 3 February 2025. 

[6]  Ministry of Maritime Affairs and Insular Policy, ‘Statement of the Ministry of Maritime Affairs and Insular
Policy in relation to the press statement of the Ombudsman’, 4 February 2025. 

[7]  Greek National Commission for Human Rights, ‘GNHRC Statement for the need to respect the
constitutionally enshrined supervisory role of the Independent Authorities’, 19 February 2025. 

[8]  Information provided to FRA by legal actors in May 2025. See also ECRE, ‘ITALY: Opening of Cutro
shipwreck trial – Court orders Italy to pay compensation to people held on coastguard vessel – Journalists’
union launches legal action against government over spyware hacking – NGOs condemn ‘illegitimate’
detention centres in Albania’, 13 March 2025. 

[9] Information provided by the Polish authorities in April 2025. 

[10]  FRA, Guidance on investigating alleged ill-treatment at borders, 30 July 2024, p. 22. 

[11] Information provided by the Croatian authorities in May 2025. 

[12] Information provided by the Hungarian authorities in April 2025. 

[13]  Frontex, The Fundamental Rights Officer – Annual report 2024, July 2025, Section 3.2. 

[14]  For a short overview, see Frontex, ‘Fundamental rights at Frontex’. The serious incident reporting is
based on the requirement set out in Article 38(3)(h) of Regulation (EU) 2019/1896. Fundamental rights
violations are one of four categories of serious incidents. 

[15]  Frontex, The Fundamental Rights Officer – Annual report 2024, July 2025, Section 3.1. 

[16] Ibid. 

[17]  See Judgment of the First Section of the ECtHR of 18 November 2021, M. H. and Others v. Croatia,
Nos 15670/18 and 43115/18; Judgment of the First Section of the ECtHR of 7 July 2022, Safi and Others v.
Greece, No 5418/15; Judgment of the First Section of the ECtHR of 2 February 2023,  Alhowais v. Hungary,
No 59435/17; Judgment of the Third Section of the ECtHR of 16 January 2024, Douaa Alkhatib and Others v.
Greece, No 3566/16; Judgment of the First Section of the ECtHR of 5 October 2023,  Shahzad v. Hungary
(No 2), No 37967/18; Judgment of the Third Section of the ECtHR of 7 January 2025, A.R.E. v. Greece,
No 15783/21.   

19/20

About this publication

© European Union Agency for Fundamental Rights, 2025

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Agency for Fundamental Rights copyright, permission must be sought directly from the
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Luxembourg: Publications Office of the European Union, 2025

Recommended citation: FRA (2025), ​Investigating alleged  ill-treatment at the European
Unions' external borders – 2025 update, Vienna.

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