COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council EIGHTH REPORT UNDER THE VISA SUSPENSION MECHANISM
Date: 2025-12-19
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU visa policy, Schengen Agreement, asylum seeker, corruption, external border of the EU, foreign national, illegal migration, organised crime, return migration, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.12.2025  SWD(2025) 429 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document Report from the Commission to the European Parliament and the Council EIGHTH REPORT UNDER THE VISA SUSPENSION MECHANISM {COM(2025) 792 final}  
 
 
Contents 

I. 

THE EU’S NEIGHBOURHOOD .....................................................................................................3 

VISA-FREE FOR LESS THAN 7 YEARS ..................................................................................................3 

   KOSOVO* ...................................................................................................................................................3 

VISA-FREE FOR MORE THAN 7 YEARS ...............................................................................................8 

   ALBANIA ....................................................................................................................................................8 

   BOSNIA AND HERZEGOVINA ............................................................................................................ 11 

   GEORGIA ................................................................................................................................................. 14 

   REPUBLIC OF MOLDOVA ................................................................................................................... 20 

   MONTENEGRO ...................................................................................................................................... 23 

   NORTH MACEDONIA ........................................................................................................................... 26 

   SERBIA ..................................................................................................................................................... 28 

   UKRAINE ................................................................................................................................................. 31 

II. 

EASTERN CARRIBEAN ............................................................................................................... 35 

III.  LATIN AMERICA .......................................................................................................................... 38 

*   This designation is without prejudice to positions on status, and is in line with UNSCR 1244/1999 and the ICJ 

Opinion on the Kosovo declaration of independence. 

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INTRODUCTION 

Article 8(4) of the Regulation (EU) 2018/1806 (the ‘Visa Regulation’) requires the Commission 
to ensure the monitoring of the continuous fulfilment of the visa exemption requirements by those 
countries whose nationals obtained visa-free access to the EU following the successful completion 
of a visa liberalisation dialogue.   

This Staff Working Document includes a full assessment of the continuous compliance with the 
visa liberalisation requirements for Kosovo, as it completed its visa liberalisation dialogues less 
than seven years ago. As regards the countries of the EU’s neighbourhood that completed a visa 
liberalisation dialogue more than seven years ago (Albania, Bosnia and Herzegovina, Moldova, 
Montenegro, North Macedonia, Serbia, Georgia and Ukraine), the staff working document flags 
specific challenges linked to visa-free travel and/or being of concern for the EU.  

The  staff  working  document  also  covers  other  geographical  areas  beyond  the  EU’s  immediate 
neighbourhood  (Eastern  Caribbean  and  Latin  America),  focusing  on  visa-free  countries  where 
specific migration and/or security related issues have arisen, that could be assessed under the visa 
suspension mechanism.  

Statistical data was provided by Eurostat and covers Schengen associated countries, explaining 
slight differences with the enlargement report. 

The  revised  visa  suspension  mechanism,  entering  into  force  end  December  2025,  introduces 
several modifications, in particular several new grounds for suspension: 

• 

• 

lack of alignment of a country’s visa-free regime with the EU’s visa policy, in cases 
where this may lead to increased illegal migration risks 
the  operation  of  an  investor  citizenship  scheme,  whereby  citizenship  is  granted  in 
exchange  for  pre-determined  payments  or  investments,  without  the  person  concerned 
having any genuine link to that third country; 
systemic deficiencies in document security, law and procedures; 

• 
•  a  deterioration  in  the  EU’s  relations  with  a  third  country,  for  a  number  of  reasons 
including  hybrid threats, serious breaches of the  UN Charter and international law, and 
human rights and humanitarian law violations. 

2 

 
 
 
 
 
 
I.  THE EU’S NEIGHBOURHOOD 

VISA-FREE FOR LESS THAN 7 YEARS 

KOSOVO 

1.  Visa policy alignment 

Since  the  EU  lifted  the  visa  requirement  for  Kosovo  citizens  as  of  January  2024,  Kosovo 
reinstated  visa  requirements  for  Botswana,  Namibia,  and  South  Africa  in  August  2024. 
Nevertheless,  the  list  of  third  countries  visa-free  in  Kosovo  while  visa  required  in  EU  still 
comprises 17 countries: Bahrain, Belize, Eswatini, Fiji, Guyana, Jordan, Kuwait, Lesotho, Malawi, 
Maldives, Oman, Papua New Guinea, Qatar, São Tomé and Príncipe, Saudi Arabia, Türkiye and 
Vanuatu (removed from the EU’s visa-free list in December 2024). 

Visa policy alignment is a key commitment of Kosovo under its Reform Agenda, as part of the 
Growth Plan for the Western Balkans.1 In this context, Kosovo has committed to transferring 
at least one country per year from this list to the visa-required category between 2025 and 2027. 

1   SWD(2024) 243 final – Commission Implementing Decision approving the Reform Agendas and the multiannual 

work programme under the Reform and Growth Facility for the Western Balkans – Kosovo. 

3 

 
 
 
 
 
Kosovo must make substantial additional efforts to align its visa policy with that of the EU, 
as  the  current  lack  of  alignment  presents  a  continued  risk  of  illegal  migration  to  the  EU, 
particularly via the Western Balkan route. While Kosovo has committed to adopting additional 
security  screening  measures  for  visa-free  third-country  nationals  assessed  as  posing  a  high 
migration risk, these measures have yet to be operationalised. Moreover, even when implemented, 
such interim measures cannot substitute for its full visa policy alignment with the EU.  

Kosovo currently issues biometric travel documents which meet EU requirements on security 
features and biometrics in travel documents. Kosovo no longer issues non-biometric passports, 
and such documents have not been in circulation since 2021. 

A new Law on Identity Cards was approved by the Parliament in 2024.  A new Administrative 
Instruction on the Issuance of Identity Cards, adopted in 2023, is currently being implemented. 

Despite these developments, as part of the consultation for this Report, three Member States have 
reported concerns regarding document security, such as 1) instances of documents issued under 
false  identities,  allegedly  facilitated  through  corrupt  practices;  2)  detection  of  false  or  forged 
identity and travel documents and 3) cases of Kosovo citizens subject to alerts in the Schengen 
Information System (SIS), who subsequently obtained travel documents with changed names or 
surnames. Kosovo Police continues to cooperate with international partners by reporting lost and 
stolen passports to Interpol (a total of 4,531 in 2023 and 7,485 in 2024).  

2. 

Integrated border management, migration management, asylum 

Following  the  three  IBM  strategies  covering  the  period  2009–2024,  a  new  Strategy  for 
Integrated Border Management (2024–2029) has been drafted, aligned with the EU concept on 
European  Integrated  Border  Management  (EIBM),  and  compliant  with  Regulation  (EU) 
2019/1896 on the European Border and Coast Guard (EBCG). The draft strategy is currently 
in the final stages prior to adoption.  

The  National  Centre  for  Border  Management  (NCBM),  established  in  2013,  continued  to 
function  as  a  coordination/support  body  for  law  enforcement  agencies.  The  Passenger 
Information Unit (PIU), housed within the NCBM, collaborated with competent authorities in 
managing Advance Passenger Information (API) and Passenger Name Record (PNR) requests 
related to terrorism, narcotics, organised crime, human smuggling, and border security. The EU–
Kosovo Stabilisation and Association Agreement, in force since 2016, provides the basis for 
cooperation  between  the  EU  and  Kosovo.  Kosovo  remained  positively  engaged  in  the 
implementation of the EU Action Plan on the Western Balkans. 

Cooperation  with  Frontex,  which  began  in  2016,  has  been  overall  satisfactory,  with  Kosovo 
actively participating in IPA-funded regional projects such as “EU Regional Support to Strengthen 
Border  Security  Capacities  in  the  Western  Balkans”  and  “EU  Regional  Support  to  Protection-
Sensitive Migration Management in the Western Balkans and Türkiye”. Cooperation with Albania 
and North Macedonia on joint border controls and joint patrolling continued.  

Regarding  readmission  cooperation,  overall  good  cooperation  was  reported,  although  two 
Member States noted delays in some cases, and one Member State reported refusals by Kosovo to 
accept EU travel documents upon the expiry of the deadline set out in the readmission agreement, 

4 

 
 
resulting in the need to restart the procedure. Cooperation between Kosovo’s Ministry of Internal 
Affairs and the European Union Agency for Asylum (EUAA) also continued. In March 2024, 
the implementation deadline of the 2022 Roadmap was extended by one year. Monitoring trends 
in migration, applications for international protection, and readmission 

With the entry into force of visa-free travel for holders of Kosovo passports on 1 January 2024, 
the  number  of  applications  for  international  protection  lodged  by  Kosovo  citizens  in  EU 
Member States increased significantly — by 121%, from 3,075 in 2023 to 6,785 in 2024. This 
upward  trend  has  shown  signs  of  slight  decline  since  the  end  of  2024.  The  recognition  rate 
dropped from 10% in 2023 to 6% in 2024. 

Kosovo has shown continued engagement with Schengen Member States to address the increase 
in  unfounded  asylum  applications  and  has  maintained  a  communication  campaign  informing 
citizens of their rights and obligations under the visa-free regime. 

An  Early  Warning  Mechanism  for  Monitoring  Migration  Trends  was  established  in 
December 2023, in the run-up to visa liberalisation. It maintains regular communication with 
Schengen  countries’  consular  and  diplomatic  representations  in  Kosovo,  holding  periodic 
meetings and producing reports on migration trends. 

In 2024, illegal border crossings by Kosovo citizens remained negligible, as in 2023. However, 
the number of Kosovo citizens found to be illegally staying in Member States rose by 20%, from 
5,275 in 2023 to 6,345 in 2024. In addition, refusals of entry for Kosovo citizens in Member States 
increased by 176%, from 1,865 in 2023 to 5,145 in 2024.  

The number of return decisions issued to Kosovo citizens decreased by 19%, from 3,775 in 2023 
to 3,050 in 2024. Nonetheless, the number of actual returns rose from 1,610 in 2023 to 2,025 in 
2024 (a 26% increase). The return rate improved from 43% in 2023 to 66% in 2024.  

The administrative instruction on the procedure of issuance of passport and return travel document 
was  amended  in  June  2024  to  facilitate  return  of  Kosovo  citizens  who  reported  lost  travel 
documents abroad. 

5 

 
 
 
Source: Eurostat 

3. 

Public order and security 

Respectively  in  March  and  June  2024  Kosovo  adopted  the  Strategy  and  Action  Plan  on  the 
Control of Small Arms, Light Weapons and Explosives (2024–2028) and the National Strategy 
against Drugs (2024–2028). Kosovo adopted the Law on Beneficial Ownership and a Law on 
Cryptocurrencies. Kosovo is also awaiting a ruling from the Constitutional Court regarding the 
Law on the State Bureau for Verification and Confiscation of Unjustifiable Assets, as well as a 
Law  on  Prevention  of  Money  Laundering.  In  addition,  Kosovo  prepared  a  new  Community 
Safety Strategy and Action Plan 2025-2029. 

Kosovo  adopted  a  series  of  implementing  laws  in  2024–2025  aimed  at  strengthening  the  fight 
against corruption, including Regulation on Asset Recovery, Regulation on the Selection of the 
Chief State Prosecutor and Chief Prosecutors as well as Regulation on Joint Investigative Teams. 
Additionally, a Strategic Plan for the Efficiency of Handling Cases of Corruption, Abuse of 
Official Duty, and Organised Crime (2025–2027) was adopted. 

In the context of fight against corruption Kosovo’s prosecution offices in 2024 received 575 new 
cases involving 1,324 individuals and resolved 386 cases involving 933 individuals.  

Cooperation  with  Europol  continued  and  was  reinforced  with  the  signing  of  additional 
agreements/protocols  on  Secure  Communication  Line  through  SIENA-channel  and  the 
secondment of Liaison Officers and the exchange and protection of classified information. The 
information exchange via SIENA doubled compared to 2023 and is six times higher than in 2022. 
Under the 2024–2025 cycle, Kosovo Police participated in 12 Operational Action Plans and 72 
Operational Actions of EMPACT: Kosovo cooperates with Liaison Prosecutors from Eurojust 
countries, although there is not yet a dedicated agreement of cooperation with Eurojust.  

6 

 
 
 
Kosovo remained engaged in the implementation of the Joint Action Plan on Counter Terrorism 
for the Western Balkans and in discussions on the preparation of the new Joint Action Plan that 
was signed on 30 October 2025.  

Kosovo continues to implement its 2017 working arrangement with CEPOL, and participates 
in  CEPOL  training  activities,  including  those  under  the  EU-funded  “Western  Balkans 
Partnership Against Crime and Terrorism” project. 

4.  Fundamental rights 

The new Law on the Independent Media Commission, adopted by the Assembly in July 2024, 
was annulled by the Constitutional Court on grounds of incompatibility with the Constitution 
of  Kosovo.  The  law  had  raised  concerns  from  political  actors  regarding  the  independence, 
mandate, financing, and the clarity and proportionality of the regulator’s powers.  

The  Ombudsperson  Institution  of  Kosovo  (OIK)  operates  under  a  robust  legal  framework 
aligned  with  the  Paris  Principles  and  the  Venice  Principles.  To  advance  the  rule  of  law, 
Kosovo’s Ministry of Justice, the Judicial and Prosecutorial Councils, the Supreme Court, 
and the acting Chief State Prosecutor signed a Joint Statement of Commitment and action plan 
in  March  2023,  providing  for  a  series  of  assessments  and  legislative  revisions  to  improve  the 
systems  of  performance  evaluation,  disciplinary  sanctions,  recruitments  and  appointments, 
integrity checks, status, professional development, and asset declarations. Following EU advice, 
the government consulted the Venice Commission which provided recommendations. In the area 
of the rights of non-majority communities, the Office for Good Governance (OGG) within the 
Office  of  the  Prime  Minister  reviewed  the  2025–2026  Action  Plan  under  the  Strategy  for  the 
Advancement of the Rights of the Roma and Ashkali Communities (2022–2026). Measures were 
undertaken to enforce legal provisions ensuring equal opportunities for all citizens. 

7 

 
 
 
 
VISA-FREE FOR MORE THAN 7 YEARS 

ALBANIA 

1.  Visa policy alignment 

Albania maintains a visa-free regime with 11 countries of visa-required in the EU, six with 
permanent visa exemption (Armenia, Azerbaijan, China, Kazakhstan, Kuwait, and Türkiye) and 
five with  seasonal visa waivers allowing entry from 15 April to 31 December 2025 (Oman, Qatar, 
Saudi Arabia, Thailand, and Indonesia), although seasonal visa waivers are not compatible with 
the EU acquis. Additionally, Albania grants visa-free access to third-country nationals who hold a 
10-year residence permit in the United Arab Emirates, provided the permit is valid for at least one 
year at the time of entry. 

Albania removed Russia, India, and Egypt from its list of seasonal visa exemptions in April 2023 
and revoked its visa-free agreement with Guyana in July 2024. In April 2025, Albania revoked the 
visa-free  regime  with  Belarus  and  removed  Bahrain  from  its  seasonal  visa-free  list.  However, 
Albania added Indonesia to the seasonal visa-free list in March 2024.  

Under  the  Reform  Agenda  of  the  Growth  Plan  for  the  Western  Balkans,  Albania  has 
committed to terminate visa-free agreements with at least two countries that are on the EU list 
of visa-required countries in 2025, at least one in 2026 and at least one in 2027, without further 
extending visa-free agreements to other countries.  

The lack of full alignment with the EU visa policy continues to pose security and migration 
risks, particularly along the Western Balkan route. Therefore, the Commission expects faster 
and more decisive progress from  Albania on visa policy alignment. Pending full  alignment, 
Albania  must  urgently  strengthen  the  screening  of  visa-free  arrivals  of  nationals  from  third 
countries presenting illegal migration or security risks. 

Furthermore,  the  visa  issuance  process  requires  improvement.  In  2024  and  2025,  numerous 
migrants from Asian countries (notably Bangladesh and Pakistan) arrived illegally in the EU and 
Schengen countries after legally entering Albania with valid visas, including long-term visas with 
work permits. The Commission urges Albania to enhance its visa issuing procedures, aligning with 
EU best practices in visa processing and risk assessment. 

2.  Monitoring  trends  in  illegal  migration,  applications  for  international  protection, 

returns and readmission  

In 2024, the number of applications for international protection lodged in EU Member States 
by Albanian nationals decreased by 22%, with 7,140 applications compared to 9,095 in 2023. 
The recognition rate declined from 10% in 2023 to 7% in 2024. 

Member States reported 640 illegal border crossings by Albanian nationals in 2024, maintaining 
levels similar to those in 2023. The number of Albanian nationals found to be illegally staying in 
Member States decreased by 10%, from 33,685 in 2023 to 30,345 in 2024. 

8 

 
 
The number of refusals of entry remained relatively stable, but at a very high level, with 13,370 
refusals in 2024, compared to 13,560 in 2023. 

As for return procedures, 15,100 return decisions were issued in 2024, marking a 14% decrease 
from 17,465 in 2023. A total of 8,130 returns of Albanian nationals were reported in 2024, slightly 
down from 8,230 in 2023 (a decrease of 1%). Nonetheless, the return rate improved from 47% in 
2023 to 54% in 2024, continuing the positive trend observed in recent years. 

Source: Eurostat 

3.  Cooperation on migration, border management and readmission  

Albanian  authorities  continued  departure  checks  on  their  own  nationals  travelling  to  the 
EU/Schengen area, with particular attention to minors. In 2024, the Border Police refused exit to 
6,944  Albanian  citizens,  a  7.7%  decrease  compared  to  2023  (7,521  refusals),  despite  a  14% 
increase in the total number of Albanians travelling abroad. 

In 2024, 1,394 illegal migrants were apprehended in Albania, mostly entering from Greece and 
attempting to transit through Kosovo or Montenegro to the EU. While Albania remains a transit 
country, illegal flows through its territory are smaller than those along the main Western Balkans 
route (via Serbia and Bosnia and Herzegovina). Albania took steps to strengthen the screening 
of third-country nationals, rejecting 67% of visa applications and refusing entry to 671 foreign 
citizens at the border. 

The country remained committed to the EU Action Plan on the Western Balkans and continued 
implementation of its Intersectoral Strategy for Integrated Border Management 2021–2027, 
along with the National Strategy for Migration 2024–2030 and its corresponding Action Plan 
(2024–2026). 

9 

 
 
 
 
Albania enhanced cooperation with Frontex, following the entry into force in June 2024 of the new 
Status  Agreement  signed  in  September  2023.  This  enabled  the  deployment  of  standing  corps 
officers at all of Albania’s borders. A Frontex Liaison Officer based in Tirana covers Albania, 
Kosovo,  and  North  Macedonia.  Border  and  immigration  services  benefited  from  EU  support, 
including equipment and specialised training. Albania continued to implement the EU-Albania 
Readmission  Agreement.  Member  States  reported  effective  cooperation  with  Albania  on 
readmission, with no major issues flagged. 

Albania maintained its cooperation with the EU Agency for Asylum (EUAA). A Roadmap 
(2024–2027) endorsed by Albanian authorities in October 2024 is being implemented. Albania has 
the required institutions in place to handle asylum claims. The asylum law and its bylaws still need 
to be implemented effectively. 

Member  States  and  Schengen-associated  countries  raised  concerns  about  cases  of  Albanian 
nationals  evading  Schengen  Information  System  (SIS)  alerts  by  changing  their  surnames,  a 
practice that undermines the system’s effectiveness. 

4.  Actions taken on unfounded asylum applications   

Albania continued to implement the 2022 Inter-institutional Action Plan “On the Prevention of 
the  Asylum-Seeking  Phenomenon  of  Albanian  Citizens  in  the  Schengen/EU  countries”,  and  to 
maintain close bilateral cooperation with the most affected EU Member States. In parallel, Albania 
reinforced border checks on Albanian citizens travelling to the Schengen area (see above). The 
rules  governing  entry  and  stay  in  the  EU,  as  well  as  the  consequences  of  violations,  including 
deportation for abuse of the asylum system, were broadly publicised in national media. 

Albania  cooperated  also  with  regional  counterparts  to  address  the  issue  of  Albanian  citizens 
seeking to bypass stricter controls by travelling through neighbouring countries before entering 
the EU. 

These measures appear to be yielding results. In 2024, the number of asylum applications lodged 
by Albanian nationals in the EU decreased compared to 2023.  

5.     Cooperation on security 

In 2024, Albania continued cooperation with EU agencies, including Europol, Frontex, Eurojust, 
CEPOL, as well as with several EU Member States, in the fight against serious, organised and 
transnational  crime.  Albania  actively  participated  in  19  Joint  Investigation  Teams  (JITs), 
targeting a broad range of criminal activities, including trafficking in human beings (notably for 
sexual exploitation), synthetic drug production and trafficking, drug smuggling, etc. Albania has 
generally provided a high level of cooperation with all partner countries involved.  

Albania  should  make  more  use  of  the  CEPOL  training  activities  enabled  by  its  working 
arrangement  with  the  agency  and  integrate  the  gained  knowledge  and  competencies  into  the 
national law enforcement training system 

10 

 
 
Albania  remained  engaged  in  the  implementation  of  the  Joint  Action  Plan  on  Counter 
Terrorism for the Western Balkans and in discussions on the preparation of the new Joint Action 
Plan that was signed on October 2025. 

6.  Citizenship by investment  

Albania did not establish any investor citizenship scheme but only suspended instead of repealing 
the relevant legal basis. The Commission will continue to monitor this issue closely. 

BOSNIA AND HERZEGOVINA 

1.  Visa policy alignment 

Bosnia and Herzegovina maintains a permanent visa-free regime with seven third countries 
which  are  visa  required  in  the  EU  (Azerbaijan,  China,  Qatar,  Russia,  Türkiye,  Kuwait  and 
Vanuatu, removed from the EU’s visa-free list in December 2024). 

Bosnia and Herzegovina introduced visa requirements for citizens of Bahrain (September 2023) 
and Oman (March 2024). However, in April 2025 a seasonal visa-waiver was granted to Bahrain 
and Oman and renewed for Saudi Arabia. Such seasonal visa waivers are not compatible with the 
EU  acquis.  Bosnia  and  Herzegovina  committed  to  terminate  one  visa-free  agreement  per  year 
during the period of 2025-2027.  

The lack of full alignment of Bosnia and Herzegovina’s visa policy with that of the EU poses a 
significant risk of illegal migration via the Western Balkans route, particularly with regard to 
nationals of Türkiye, of whom 4 988 were intercepted in 2024 while attempting to illegally cross 
Bosnia  and  Herzegovina  -  Croatia  border.  The  Commission  expects  substantial  progress  by 
Bosnia and Herzegovina towards full visa policy alignment. 

Bosnia  and  Herzegovina  introduced  biometric  visa  applications  as  of  1  October  2025  in  its 
diplomatic network and work on fully operationalising its central visa information system. Upon 
introduction of the biometric visa applications, local authorities actively work on engagement of 
external service providers to make visa application process more efficient as per EU acquis and 
best practices.  

Pending  full  alignment,  Bosnia  and  Herzegovina  should  adopt,  as  a  minimum  temporary 
measure,  a  more  rigorous  screening  process  for  visa-free  arrivals,  focusing  especially  on 
nationals of countries assessed to pose elevated risks related to illegal migration or security. In 
addition,  authorities  are  encouraged  to  intensify  the  establishment  of  passenger  data  exchange 
(API/PNR) systems. 

11 

 
 
 
 
2.  Monitoring  trends  in  illegal  migration,  applications  for  international  protection, 

returns and readmission 

In 2024, 1,445 applications for international protection were submitted by nationals of Bosnia 
and Herzegovina in EU Member States, representing an 11% decrease compared to 2023 (1,620). 
This continues the downward trend observed since 2021.The recognition rate remained stable (6% 
in 2023, 5% in 2024). 

The  number  of  illegal  border  crossings  by  Bosnian  nationals  remained  marginal  (78  in  2024, 
compared to 20 in 2023). The number of Bosnian nationals found to be illegally staying in Member 
States  declined by 7% (3,940 in 2023, compared to 3,665 in 2024). 

The number of refusals of entry increased by 26%, from 4,010 in 2023 to 5,070 in 2024. 

The number of return decisions issued to Bosnian nationals increased slightly in 2024 to 2,520, 
up from 2,465 in 2023 (+2%). The number of returns carried out also increased  to 1,275, compared 
with 1,230 in 2023 (+4%). The return rate remained stable  (50% in 2023, 51% in 2024). 

Source: Eurostat 

3.  Cooperation on migration, border management and readmission 

In 2024, the border between Bosnia and Herzegovina and Croatia remained the busiest entry 
point  for  illegal  migrants  seeking  access  to  the  European  Union  through  the  Western  Balkans 
route.  Croatia  reported  an  increase  in  illegal  border  crossings  from  Bosnia  and  Herzegovina 
(18,279 compared to 14,957 in 2023, +22%).   

12 

 
 
 
Citizens of Armenia, Georgia2, Kazakhstan, Kyrgyzstan, Tajikistan, and Uzbekistan were detected 
using  Russian  passports  to  enter  Bosnia  and  Herzegovina  visa-free.  Fraudulent  Turkish 
passports were used by Afghan nationals to enter Bosnia and Herzegovina with the objective to 
illegally cross into EU Member States. 

Nationals of various third countries which are visa-required in EU were reported entering Bosnia 
and Herzegovina with visas or work permits based on fraudulent employment contracts with 
purpose to attempt illegal entry into the EU. 

Bosnia and Herzegovina constructively participated in the EU Action Plan on the Western 
Balkans. The adoption of a Law on foreigners in 2023, a Law on border control in January 
2025, and a strategy for integrated border management 2024–2029 in July 2025 marked steps 
towards alignment with EU standards. 

Bosnia  and  Herzegovina  signed  a  Frontex  status  agreement  with  the  EU  on  11  June  2025. 
Operational  cooperation  with  Frontex  resulting  in  deployment  of  Standing  Corps  officers  that 
officially started on 29 October 2025, notably including deployments at Sarajevo International 
Airport, supported by the Frontex liaison officer in Belgrade. 

Bosnia and Herzegovina increased the number of police personnel  along  its  borders but is still 
facing significant staff shortages. EU Member States provided technical assistance, training, and 
coordinated patrols, yet the mountainous terrain is a challenge to effective control, especially 
along the long border with Croatia. Once migrants enter Bosnia and Herzegovina, many manage 
to cross into the EU undetected.  

In 2024, Bosnia and Herzegovina carried out 508 voluntary returns (123 in 2023) and 14 forced 
returns (43 in 2023). 

Cooperation on readmission  was  generally positive in  2024,  when . Bosnia and Herzegovina 
accepted 3,255 migrants returned from Croatia under the bilateral readmission agreement (2,458 
in  2023).  However,  two  Member  States  reported  delays  and  low  identification  rates  (around 
55%), primarily due to false identities and obstruction by returnees. 

On 11 June 2025, Bosnia and Herzegovina adopted a strategy for the reception and integration 
of citizens returning under readmission agreements, along with an action plan for 2024–2026. 
This framework aims to establish a sustainable, rights-based return and reintegration system 
to reduce illegal migration and enhance societal reintegration. 

Bosnia  and  Herzegovina  also  maintained  its  cooperation  with  the  EU  Agency  for  Asylum 
(EUAA). A second Roadmap (2025–2027) has been developed jointly by the Ministry of Security 
of Bosnia and Herzegovina and the EUAA to strengthen local asylum and reception system. 

2  

In case of citizens of Georgia, who can enter visa-free both EU and Bosnia and Herzegovina, the use of fake 
Russian passports is of interest essentially to those subject to interdiction of entry into EU.   

13 

 
 
 
 Cooperation on security 

In  2024,  Bosnia  and  Herzegovina  continued  to  cooperate  with  Europol,  including  through  its 
liaison officer based in  the Hague and the regular exchange of information via the SIENA 
communication system, focusing particularly on the fight against migrant smuggling, with 24 
joint  operations  reported.  Cooperation  with  EU  continued  also  through  the  European 
Multidisciplinary Platform Against Criminal Threats (EMPACT) - with particular emphasis 
on the trafficking of firearms - and through Interpol channels. 

An area of concern is the production and distribution of forged identity documents including 
passports and driving licences of various EU Member States - by criminal groups operating in 
Bosnia and Herzegovina.  

In 2024 Bosnia and Herzegovina continued implementation of the Joint Action Plan on Counter 
Terrorism (JAP), however some objective remained unimplemented and need to be addressed by 
BiH in the framework of the new JAP, which was signed on 30 October 2025.  

GEORGIA 

1.  Visa policy alignment 

Georgia maintains a visa-free regime with 26 countries visa-required in EU: Armenia, Azerbaijan, 
Bahrain, Belarus, Belize, Botswana, China (since April 2024), Dominican Republic, Ecuador, Fiji, 
Iran,  Jordan,  Kazakhstan,  Kuwait,  Kyrgyzstan,  Lebanon,  Oman,  Qatar,  Russia,  Saudi  Arabia, 
South Africa, Tajikistan, Thailand, Türkiye, Turkmenistan, and Uzbekistan. 

Georgia  continues  to  pursue  a  visa  policy  that  diverges  substantially  from  the  EU  acquis, 
particularly by granting entry to nationals of countries visa-required both in the EU and in Georgia 
on  the  basis  of  a  visa  or  residence  permit  issued  by  a  third  country.  Georgian  authorities 
themselves acknowledged that this practice creates a risk of illegal secondary migration, both 
into Georgia and onward to the European Union. In response, and as of 16 May 2025, Georgia 
introduced a partial restriction by limiting this practice to nationals of 17 high-risk countries 
(Afghanistan,  Bangladesh,  Cameroon,  the  Democratic  Republic  of  Congo,  Ghana,  Eritrea, 
Ethiopia, Côte d'Ivoire,  Morocco, Nigeria, Pakistan, Somalia, Sudan, Syria, Tanzania, Uganda, 
and Yemen) only if they hold a visa or residence permit valid for less than one year, issued by 
one of the Gulf Cooperation Council (GCC) countries.  

This measure is insufficient.  The practice must be fully discontinued, in line with EU norms. 

No progress has been made by Georgia in aligning its visa policy with the EU acquis between 
2021 and 2024 despite recommendations contained in successive Visa Suspension Mechanism 

14 

 
 
 
reports3. The signature of a visa waiver agreement with China in April 2024 has widened the 
gap between Georgia’s visa regime and that of the EU. 

The alignment with the EU’s visa policy is a core requirement for all countries in the EU’s 
neighbourhood benefiting from visa-free travel to the Schengen area. The continued absence 
of tangible progress in this area shows the lack of commitment of Georgian authorities to comply 
with its obligations towards the EU as a visa-free country. 

2.  Monitoring trends in illegal migration, applications for international protection, returns 
and readmission 

In 2024, the number of applications for international protection lodged in Member States by 
nationals  of  Georgia  decreased  by  40%  compared  to  2023,  yet  remaining  at  a  high  level,  with 
14,530 applications lodged (compared to 24,350 in 2023). The recognition rate remained stable 
at 7%, unchanged from the previous year. 

Illegal border crossings by Georgian nationals continued to be marginal (10 reported in 2023 and 
29 in 2024). The number of Georgian nationals found to be  illegally staying in Member States 
remains high but decreased, falling to 20 200 from 24,965 in 2023.  Refusals of entry issued to 
Georgian nationals increased from 3,730 in 2023 to 4,460 in 2024. 

The number of return decisions issued to Georgian nationals declined from 20,165 in 2023 to 
17,375 in 2024. The number of effective returns increased, reaching 11,525 in 2024 (10,195 in 
2023). The return rate improved, rising from 51% in 2023 to 66% in 2024. 

Source: Eurostat 

3   Fourth VSM Report (4 August 2021), Fifth VSM Report (5 December 2022), Sixth VSM Report (18 October 

2023) and Seventh VSM Report (6 December 2024).   

15 

 
 
 
 
3.  Cooperation on migration, border management and readmission 

Following the conclusions of the European Council of June 2024, that the Georgian authorities’ 
course of action jeopardises Georgia’s EU path, most forms of EU cooperation with the Ministry 
of Interior and security agencies were suspended. 

Cooperation  with  Frontex  has  remained  active,  notably  through  the  ongoing  deployment  of 
advisers and observers in Georgia and the joint execution of Operation Georgia 2024, carried 
out  under  the  Working  Arrangement  renewed  in  2021.  However,  further  renewal  of  this 
Arrangement is not foreseen in the foreseeable future. 

Georgia remains a member of the Eastern Partnership Risk Analysis Network (EaP-RAN), a 
Frontex-led  platform  for  intelligence-sharing  and  regional  cooperation  on  risk  analysis. 
Georgian border authorities also participated in several Frontex-led specialised training sessions 
throughout 2024 and continued their involvement in the Air Borders Risk Analyses Network 
(AB-RAN). 

Georgia's level of cooperation on readmission and returns in 2024 remained high, particularly 
considering  the  number  of  returnees.  In  May  2024,  Georgia  introduced  an  electronic  case 
management  system  –  the  Georgia  Readmission  Case  Management  System  (RCMS)  – 
enabling faster and more efficient processing of readmission requests and the issuance of travel 
documents.  

Illegal migration of Georgian nationals to the EU remains high (see above). In particular, the issue 
of Georgian nationals remaining illegally in the EU to access medical care or to apply for asylum 
on medical grounds continues to be a serious issue of concern. Since 2021, Georgia has undertaken 
notable efforts to curb illegal migration to the EU, including the adoption of an Entry-Exit Law, 
implementation  of  information  campaigns,  exit  controls  to  verify  the  fulfilment  of  entry 
conditions  in  the  Schengen  area,  and  the  deployment  of  Frontex  officers  at  Georgian 
airports.  Nonetheless,  the  increase  in  refusals  of  entry  to  Georgian  citizens  in  2024  reflects 
persisting vulnerabilities in pre-departure awareness and control mechanisms. 

One EU Member State has flagged security and illegal migration concerns linked to a significant 
influx  of  nationals  from  India  and  Pakistan  into  Georgia.  Georgia  itself  is  under  increasing 
migratory pressure, including cases of migrant smuggling. In April 2024, the country revised its 
border and immigration legislation, introducing criminal liability for migrant smuggling and 
for facilitating illegal stay. On 27 December 2024, Georgia adopted the Fifth Action Plan (2025) 
under  its  2021–2030  Migration  Strategy.  The  country  also  continued  implementation  of  its 
Integrated Border Management Strategy and the associated Action Plan for 2023–2027. 

Georgia  also  faces  challenges  linked  to  asylum  abuse.  In  2024,  Georgian  authorities  received 
1,641 asylum requests, primarily from nationals of Türkiye, Iran, Pakistan, Ukraine, and India, but 
only  11  applicants  were  found  eligible  for  refugee  status,  and  104  applicants  for  humanitarian 
protection.  Moreover,  Georgia  has  emerged  as  a  regional  hub  for  commercial  surrogacy,  a 
development that raises serious concerns about potential risks of human trafficking. 

In June 2025, Georgia adopted a comprehensive legislative package amending 18 legal acts related 
to the status and regulation of foreign nationals. These amendments introduce provisions whereby 

16 

 
 
acts  such as petty hooliganism committed by a foreigner, disobedience to a police officer, and 
insulting  an  official  may  constitute  grounds  for  expulsion  and  an  entry  ban  into  Georgia  for  a 
period of up to three years. The timing and context of the legislative changes raised concerns as 
similar clauses have been used against Georgian protestors during the ongoing protests. In this 
context,  Georgia  is  expected  to  ensure  that  the  rights  of  foreign  nationals  are  safeguarded, 
particularly  in  migration  management  procedures  and  in  the  assessment  of  applications  for 
international protection, through robust procedural safeguards. 

4.   Cooperation on security 

Throughout 2024, Georgia maintained active cooperation with  Europol, particularly within the 
framework of EMPACT operational activities, including information exchange and participation 
in  analytical  projects.  In  July  2024  the  Arrangement  on  the  Exchange  and  Protection  of 
Classified Information between Georgia and Europol entered into force. Georgia continued to 
implement its National Counterterrorism Strategy 2022–2026. Georgia remains a member of 
MONEYVAL4. In December 2024 MONEYVAL adopted Georgia’s Third Enhanced Follow-
up  Report, 
(Anti-Money 
Laundering/Combating  the  Financing  of  Terrorism)  framework.  However,  further  action  is 
to  fully  comply  with  outstanding  Financial  Action  Task  Force  (FATF) 
required 
recommendations.  

in  Georgia’s  AML/CFT 

acknowledging 

improvements 

Concerning document security, non-biometric passports were fully phased out as of 1 January 
2025 and replacement of non-electronic identity cards with electronic versions was completed 
in July 2024.  

There are security concerns linked to Russian influence, in the context of the growth of the 
Russian  diaspora  in  Georgia.  Since  the  onset  of  Russia’s  war  of  aggression  against  Ukraine 
approximately  160  000  Russian  citizens  have  emigrated  to  Georgia.  Georgian  airports  are 
frequently used as transit points by Russian nationals travelling to Europe. The number of direct 
flights and destinations served between Georgia and Russia has been steadily increasing since their 
restoration in 2023. There is an increasing concern that Russian presence in Georgia may be 
exploited to carry foreign influence operations.  

Another  area  of  concern  is  the  potential  misuse  of  Georgian  citizenship,  especially  when 
obtained via simplified naturalisation procedures by Russian nationals. Such cases raise both 
illegal migration risks and broader security implications for the EU. 

In  addition,  weaknesses  remain  in  Georgia’s  identity  document  management,  notably  the 
possibility for Georgian nationals to easily change names and obtain new identity documents. In 
some documented cases, individuals have reportedly changed identities up to five times, enabling 
circumvention of EU return and entry bans.  

4   Council  of  Europe’s  Committee  of  Experts  on  the  Evaluation  of  Anti-Money  Laundering  Measures  and  the 

Financing of Terrorism. 

17 

 
 
 
5.  Fight against corruption  

The Sixth Report under the  Visa Suspension Mechanism of 18 October  2023, and the Seventh 
Report of 6 December 2024 recommended that Georgia should:  

- 

- 

- 

set up an Asset Recovery Office and Asset Management Office, and continue efforts in 
asset tracing, freezing, management, confiscation and disposal. 
adopt a new anti-corruption strategy and action plan, ensuring adequate resources for their 
implementation and pay special attention to investigation, prosecution, and adjudication of 
high-level corruption cases. 

amend  the  Law  on  Anti-Corruption  Bureau  to  address  key  Venice  Commission 
recommendations, particularly those pertaining to the Anti-Corruption Bureau’s effective 
independence, political neutrality and functions.  

While  the  National  Agency  of  State  Property  (NASP)  holds  the  formal  mandate  for  the 
management of confiscated assets and the Office of Prosecutor General of Georgia has competence 
in  the  matter  of  cooperation  and  exchange  of  information  with  asset  recovery  offices  in  other 
countries, Georgia did not yet establish a dedicated Asset Recovery Office, a key institutional 
component for an effective anti-corruption framework. 

Georgia started to draft an anti-corruption strategy and action plan which would tentatively become 
operational in 2026; they are foreseen to cover the periods 2026-2030 and 2026-2028 respectively, 
however, no comprehensive anti-corruption strategy and action plan exist currently. 

The recommendations from the Fifth Evaluation Round of the Council of Europe’s Group of 
States against Corruption (GRECO), which included amongst others the introduction of a 
code  of  conduct  for  persons  entrusted  with  top  executive  functions,  remain  only  partially 
implemented. 

As noted already in the Seventh Report under the Visa Suspension Mechanism, the Law on 
the Anti-Corruption Bureau (ACB), adopted in May 2024, did not sufficiently address the 
core  recommendations  of  the  Venice  Commission,  particularly  concerning  the  ACB’s 
independence, political impartiality, and operational scope. 

On 18 November 2025 Georgian authorities announced that Anti-Corruption Bureau, created in 
2022, will be abolished on 2 March 2026, and its functions transferred to the State Audit Office.  

Considering these developments, it is evident that the recommendations outlined in the Seventh 
Report  regarding  anti-corruption  remain  unimplemented  and  the  integrity  framework  in 
Georgia has further progressed in a manner inconsistent with EU standards.  

6.   Fundamental rights 

The adoption of the Law “On Transparency of Foreign Influence” in May 2024, followed by 
the  legislative  package  on  “Family  Values  and  Protection  of  Minors”  in  September  2024, 
contributed  to  a  significant  deterioration  in  relations  between  the  EU  and  Georgia.  The  EU 
considers these legislative measures to be incompatible with fundamental rights and freedoms, 

18 

 
 
notably freedom of association, freedom of assembly, freedom of expression, and the right to 
privacy. 

In view of the developments in Georgia, the European Council concluded in June and October 
2024 that the authorities’ course of action jeopardised Georgia’s EU path, de facto leading to a 
halt of the accession process.  In December 2024, the European Council regretted the Georgian 
government’s decision to suspend the country’s EU accession process until 2028. 

As a consequence of these developments, on 27 January 2025, the Council decided to partially 
suspend the application of the 2011 EU–Georgia Visa Facilitation Agreement, opening the 
possibility for Member States to take national measures  to reintroduce  a visa requirement for 
holders  of  Georgian  diplomatic,  service,  and  special  passports5.  The  Commission  adopted 
guidelines recommending Member States to introduce such a requirement on 15 February 20256. 
As  of  November  2025,  nineteen  EU  Member  States  and  Norway  notified  introduction  of  such 
requirement.   

Following the European Council’s conclusions from 17 October 2024, the Seventh Report under 
Visa Suspension Mechanism recommended the following actions to Georgia:  

-  Ensure and uphold the protection of fundamental rights of all Georgian citizens, including 
the  freedoms  of  association,  assembly  and  expression,  the  right  to  privacy,  the  right  to 
participate in public affairs, as well as the prohibition of discrimination. 

-  Avoid  and  repeal  any  legislation  that  may  restrict  fundamental  rights  and  freedoms,  go 
against  the  principle  of  non-discrimination  and  contradict  relevant  European  and 
international standards. In particular, repeal the Law on ‘transparency of foreign influence’ 
and the legislative package on ‘family values and protection of minors’, and amend the 
national  strategy  and  action  plan  on  human  rights  to  ensure  that  the  rights  of  LGBTIQ 
persons are fully upheld. 

Georgia  has  not  addressed  the  recommendations  of  the  Seventh  Report  and  has  instead 
regressed further in key areas of governance and fundamental rights, with legislative changes 
such as the Foreign Agents Registration Act (FARA) as well as amendments to the Law on Grants, 
the Law on Political Associations of Citizens, the Code on Administrative Offences, the Law on 
Broadcasting  and  the  Criminal  Code.  Collectively,  these  measures  have  served  to  restrict 
dissenting voices, including  those of  protestors,  opposition representatives, civil  society actors, 
human rights defenders and independent media, severely curtailing human rights.  

Following  the  adoption  of  the  Law  on  Transparency  of  Foreign  Influence,  the  parliamentary 
elections  of  26  October  2024  and  the  government’s  announcement  on  28  November  2024  that 
Georgia would not pursue the opening of accession negotiations until 2028, widespread protests 
erupted. During these events, demonstrators were subjected to unlawful, and excessive use of force 
by  law  enforcement,  including  cases  amounting  to  torture  and  ill-treatment.  While  no  law 
enforcement officers have been held accountable for their actions, protestors have been receiving 

5   Council Decision (EU) 2025/170 

6   C(2025) 980 final 

19 

 
 
 
disproportionate sentences revealing the political instrumentalisation of the justice system. Several 
opposition figures have been arrested and sentenced to prison and ineligibility, further threatening 
the  existence  of  a  pluralistic  democracy  in  Georgia.  The  safety  of  journalists  has  significantly 
deteriorated,  with  cases  involving  intimidation,  hate  speech,  physical  violence,  and  legal 
harassment.  These  trends  combined  with  the  effects  of  repressive  legislation  have  severely 
hampered media professionals’ ability to operate freely and independently. 

In  parallel,  Georgian  authorities  have  failed  to  acknowledge  or  address  the  systemic 
discrimination  faced  by  LGBTIQ  individuals.  Impunity  persists  for  those  who  incite  or 
perpetrate violence against LGBTIQ persons. Moreover, legal amendments in April 2025 removed 
the term “gender” from fifteen legal texts, replacing it with “equality between women and men,” 
and eliminating references to “gender identity” altogether. This marks a significant departure from 
previous efforts to align Georgia’s legal framework with international human rights standards and 
the EU gender equality acquis. 

Separately,  the  Seventh  VSM  Report  had  recommended  aligning  the  Law  on  Personal  Data 
Protection  with  the  EU  acquis,  in  line  with  Venice  Commission  guidance  on  institutional 
independence,  impartiality,  and  enforcement  powers.  However,  as  of    December  2025,  no 
legislative progress has been made in this area. 

REPUBLIC OF MOLDOVA 

1.  Visa alignment 

Moldova has currently a  visa-free regime with 11 countries that are on the EU list of visa-
required  countries  (Armenia,  Azerbaijan,  Belarus,  Kazakhstan,  Kyrgyzstan,  Qatar,  Russia, 
Tajikistan,  Türkiye,  Uzbekistan  and  Vanuatu,  which  was  removed  from  EU’s  visa-free  list  in 
February 2025). 

Moldova-Ecuador  and  Moldova-Cuba  agreements  on  visa-free  travel  were  terminated  in  April 
2024 and February 2025 respectively. Moldova declared that it will fully align its visa policy with 
the EU’s visa policy by the date of accession. In the meantime, the possibility for further alignment 
with  the  EU’s  visa  policy  will  be  assessed  yearly  as  part  of  updates  of  the  National  Plan  for 
adoption of the EU acquis.   

The  Commission  expects  Moldova  to  make  significant  further  progress  on  visa  policy 
alignment to address the illegal migration and/or security risks for the EU and its Member 
States, posed by EU visa-required countries which are on Moldova visa-free list. 

Pending full alignment, Moldova has committed to carry out more rigorous screening of visa-free 
arrivals of third-country nationals, in particular those from countries presenting security or illegal 
migration risks. 

20 

 
 
 
2.  Monitoring  trends  in  illegal  migration,  applications  for  international  protection, 

returns and readmission 

The number of applications for international protection by Moldovan nationals in Member 
States decreased, with 5,945 applications lodged in 2023 against 5,120 applications in 2024. The 
recognition rate was 2 % in 2024 (3% in 2023). 

Illegal crossings of  the EU’s external borders by Moldovan nationals trying to cross remained 
marginal (20 in 2023, 39 in 2024). The number of Moldovan nationals found to be illegally staying 
in Member States decreased from 40,270 in 2023 to 29,270 in 2024. In the same period, the number 
of Moldovan nationals refused entry rose from 9,850 in 2023 to 12,100 in 2024. 

In 2024, the number of return orders issued to Moldovan nationals decreased from 9,115 in 2023 
to 8,225 in 2024, while the number of returns increased from 3,590 in 2023 to 4,035 in 2024. The 
return rate was 49% in 2024, (39% in 2023). 

Source: Eurostat 

3.  Cooperation on migration, border management and readmission 

Despite the efforts of the Moldovan government, the country's proximity to the EU, coupled with 
its visa-free status, continues to contribute to illegal short-term labour migration and frequent 
overstays by Moldovan nationals. Moldovan citizens are consistently among the most frequently 
detected visa-free nationals found to be staying illegally within the EU.  

21 

 
 
 
 
 
Moldova continued to address the issue of illegal migration in cooperation with Frontex, Europol, 
CEPOL, and the European Union Border Assistance Mission to Moldova and Ukraine (EUBAM), 
including through the EU Support Hub for Internal Security and Border Management in Moldova.  

In the area of border management, Moldova continued its cooperation with Frontex in 2024 under 
the framework of the Status Agreement signed in March 2022. Joint Operations "Moldova 2023" 
and "Moldova 2024" were conducted between 25 January 2023 and 22 January 2025, involving 
the deployment of numerous Frontex officers at both the air border (Chișinău International Airport) 
and  land  borders  with  Romania  and  Ukraine.  A  follow-up  operation,  "Moldova  2025,"  was 
launched on 22 January 2025. 

The Frontex Liaison Officer to the Eastern Partnership countries, initially intended to be based in 
Kyiv, continues to operate from Chisinau instead, since July 2022. A European migration liaison 
officer to the Eastern Partnership countries started working in 2024.  

The  EU  and  its  Member  States  and  EU  agencies  continued  to  assist  Moldova  with  training 
(communications, cyber security, mobile border surveillance, etc.) and equipment (donated, co-
owned or leased), the latter including patrol boats, vehicles, border surveillance equipment, various 
electronics, etc. Joint border patrols with Romania continued. The law on the State border, partially 
aligned with  the  EU  acquis, has introduced provisions for the collection  of biometric data, but 
Moldova  still  needs  to  adopt  implementing  legislation  to  operationalise  the  measure  at  border 
crossing points.  

Moldova’s cooperation on readmission and returns was rated as excellent both by Frontex 
and numerous Member States, especially considering the high volume of cases treated. Travel 
documents were delivered quickly and efficiently. One EU Member State signalled some issues 
with  the  acceptation  of  third-country  returnees,  who  transited  through  Moldova  but  were  not 
residents. 

4.  Cooperation on security 

In 2024, Moldova continued to face significant security challenges, primarily as a result of the 
spillover effects of Russia’s war of aggression against Ukraine. The country has been subject 
to  a  wide  range  of  destabilising  factors,  including  hybrid  threats,  cyberattacks,  transborder 
criminal activity, and foreign interference from Russia and its proxies. 

In response, Moldova maintained intensive operational cooperation with Europol, marked by 
the deployment of a Moldovan liaison officer to Europol headquarters in 2024 and the presence 
of Europol Guest Officers in Moldova. These deployments aimed to enhance joint operational 
support and promote the exchange of expertise and best practices in combating cross-border 
organised  crime.  Moldova  remained  actively  engaged  in  the  European  Multidisciplinary 
Platform  Against  Criminal  Threats  (EMPACT)  Operational  Action  Plans  2024–2025, 
contributing to priority areas such as trafficking in human beings (including minors), migrant 
smuggling, drug trafficking, and firearms trafficking. 

Cooperation with Eurojust intensified, notably through the deployment of a Moldovan liaison 
prosecutor and participation in several joint investigation teams (JITs). In April 2025, Moldova 
further signed a new Working Arrangement with CEPOL, aimed at enhancing training and 

22 

 
 
institutional capacity. Collaboration with EUDA and bilateral partnerships with several EU 
Member States continued to focus on addressing cross-border criminality, including targeting 
the use and detection of forged and falsified documents. 

Nevertheless, security concerns remain, including regarding firearms trafficking through Moldova 
into the EU. This issue was addressed as part of the EU Support Hub for Internal Security and 
Border Management.  

MONTENEGRO 

1. 

Visa policy alignment 

As of 2025, Montenegro maintains a permanent visa-free regime for 8 countries visa-required 
in EU (Azerbaijan, Bahrain, Belarus, China, Qatar, Russia, Saudi Arabia and Türkiye) and grants 
a seasonal visa-waiver to citizens of Kazakhstan.  

Montenegro also grants a seasonal visa waiver of up to 10 days to certain third-country nationals 
holding  a  residence  permit  from  the  United  Arab  Emirates  valid  for  at  least  three  years.  
Montenegro removed Armenia, Egypt, Kuwait, Uzbekistan and Vanuatu from its visa-free 
list. in 2025, but earlier, in December 2024, granted a permanent visa-waiver to Bahrain and Saudi 
Arabia. Seasonal visa-waivers are not compatible with EU acquis and full visa policy alignment 
is  a  closing  benchmark  for  Chapter  24  of  the  EU  accession  negotiations.  In  October  2025, 
Montenegro suspended its visa free regime with Türkiye, but only as a temporary measure.7  

Montenegro has committed to reviewing existing visa-free regimes based on tourism-related 
data,  with  the  aim  of  progressively  aligning  its  visa  policy  with  that  of  the  EU.  Montenegro 
continued to pursue objectives under its Reform Agenda, notably: 

• 

• 

the  modernisation  of  its  border  and  security  information  systems,  aiming  for  full 
interoperability between systems and databases by the end of 2025; 

the  initiation  of  biometric  data  collection  for  visa  applicants,  in  preparation  for  full 
alignment with EU visa procedures, by the end of 2026. 

Under  the  Reform  Agenda,  Montenegro  has  also  committed  to  introducing,  by  June  2027, 
screening mechanisms for visa-exempt nationals considered to pose a risk of illegal migration, 
including a wider use of requirement that the nationals of certain visa-free third countries travel 
as part of a group (this measure is already in place for certain nationalities) 

7   On  27  October  2025,  in  response  to  a  domestic  incident  involving  Turkish  nationals,  the  Government  of 
Montenegro  introduced  a  temporary  visa  requirement  vis-à-vis  citizens  of  Türkiye  with  the  primary  aim  of 
preserving public order and the safety of Montenegrin citizens. As it is temporary (although with no known expiry 
date), this measure cannot, at present, be considered as a permanent termination of Montenegro’s visa-free regime 
with Türkiye. The Commission will monitor the situation as it unfolds. 

23 

 
 
 
 
2.  Monitoring  trends  in  illegal  migration,  applications  for  international  protection, 

returns and readmission  

In 2024, the number of applications for international protection lodged in EU Member States 
by  nationals  of  Montenegro  decreased  with  340  applications  submitted  (375  in  2023).  The 
recognition rate fell from 3% in 2023 to 1% in 2024.  

The number of illegal border crossings by Montenegrin nationals remained marginal(10 in 2024, 
4 in 2023). The number of Montenegrin nationals found to be illegally staying in Member States 
decreased from 1,000 in 2023 to 925 in 2024. 

Member States issued 320 entry refusals to Montenegrin nationals in 2024 (375 refusals in 2023). 

The number of return decisions issued in 2024 remained  stable at 405 (410 in 2023). The number 
of actual returns rose from 195 in 2023 to 290 in 2024 (a 49% increase). As a result, the return 
rate rose from 48% in 2023 to 72% in 2024. 

Source: Eurostat 

3.  Cooperation on migration, border management and readmission  

Montenegro adopted its new Integrated Border Management (IBM) Strategy 2025–2028, aimed at 
further  aligning  Montenegro’s  border  management  framework  with  the  EU  IBM  concept. 
Regarding readmission cooperation, Member States generally reported good collaboration with 
Montenegrin authorities. In 2024, Montenegro submitted draft Implementing Protocols to the EU-
Montenegro  Readmission  Agreement  to  ten  Member  States,  and  formal  negotiations  were 
launched with two of them. In addition, Montenegro made significant progress in 2024 in building 
communication  channels  with  key  countries  of  origin  of  illegal  migrants,  notably  Bangladesh, 
Pakistan, and Nepal, in view of enhancing readmission cooperation. 

24 

 
 
 
 
As concerns cooperation with Frontex, the annual joint operation under the framework of the 
2023  Status  Agreement  commenced  in  January  2025.  Joint  operational  activities  involving 
Montenegrin and Frontex officers have continued at border crossing points and police stations.  
Frontex  also  deployed  a  Joint  Debriefing  Team  at  the  Centre  for  Reception  of  Foreigners  and 
continues to support Montenegro’s border police with material and technical resources, including 
surveillance equipment. 

Further  efforts to  enhance  border security are being undertaken through the EU-funded project 
“Individual  Measure 
in 
Montenegro,”  implemented  by  the  International  Organisation  for  Migration.  The  2025–2027 
Roadmap  for  Cooperation  between  the  European  Union  Agency  for  Asylum  (EUAA)  and 
Montenegro was signed in March 2025. 

for  Strengthening  Integrated  Border  Management  Capacities 

4.  Cooperation on security 

Montenegro  continued  to  cooperate  with  Europol  and  strengthened  its  institutional 
framework for tackling cross-border crime. A new Interagency Working Team was established 
to plan and implement EMPACT (European Multidisciplinary Platform Against Criminal Threats) 
operational activities coordinated by Europol. Following the creation of a dedicated Group for the 
Suppression of Human Smuggling and Cross-Border Crime, Montenegro enhanced its efforts to 
combat  migrant  smuggling.  Notably,  in  2024,  it  took  part  for  the  first  time  in  a  Europol-led 
Operational Task Force (OTF) "Zebra", focused specifically on this issue. Additionally, with the 
support of the EU4FAST project, Montenegro established a new International Operational Centre 
to  serve  as  a  Single  Point  of  Contact  (SPoC)  for  coordination  and  information  exchange 
between national law enforcement authorities and international partners, including Europol 
and the law enforcement authorities of EU Member States. 

Montenegro  remained  engaged  in  the  implementation  of  the  Joint  Action  Plan  on  Counter 
Terrorism for the Western Balkans and in discussions on the preparation of the new Joint Action 
Plan that was signed on 30 October 2025.  

5. 

Investor citizenship schemes  

Montenegro’s  investor  citizenship  scheme  was  terminated  on  31  December  2022,  but 
authorities have continued to process applications for citizenship submitted before the termination 
date.  In  2024,  Montenegro’s  Ministry  of  Interior  (MoI)  has  issued  1,282  decisions  granting 
Montenegrin  citizenship  to  applicants  and  their  family  members,  which  represents  an  82,9% 
increase compared to  2023. Of those 1,282  decisions,  709 concerned individuals  holding the 
citizenship of the Russian Federation, 42 of Belarus, 35 of Türkiye, 29 of Saudi Arabia and 28 
of the People’s Republic of China. Citizenship was granted to nationals of other visa-required third 
countries  (South  Africa,  Vietnam,  India,  Egypt,  Pakistan,  Lebanon,  Thailand,  Philippines, 
Senegal, Eritrea, Azerbaijan, Ivory Coast, Jordan,  Bahrain, Armenia,  Iran, Sudan, United Arab 

25 

 
 
   
Emirates, Vanuatu,  Indonesia, Kazakhstan).8  The MoI also  issued 31 negative decisions.  As of 
April 2025, 29 applications were being processed by the MoI.  

The processing of applications for citizenship involves checks by Montenegro’s National Security 
Agency regarding the existence of security-related circumstances; checks by the Police Directorate 
against  Interpol  and  Europol  databases;  and  checks  by  Montenegro’s  Ministry  of  Justice  on 
national criminal records. 

Necessary security checks are required while analysing the remaining applications for citizenships 
under the provisions of the investor citizenship scheme and ensure that the citizenship granted to 
persons subject to international restrictive measures are revoked.  

The Commission will continue to monitor any developments in the processing of applications for 
citizenship, with a particular focus on those presenting a security risk, until all pending applications 
have been processed. 

NORTH MACEDONIA 

1.  Visa policy alignment 

Türkiye remains the only third country that is visa-free for North Macedonia while being 
visa-required  under  the  EU  visa  regime.  North  Macedonia  is  therefore  very  near  to  full 
alignment of its visa policy with EU visa policy.  

North Macedonia has committed to introducing additional security measures by 2027 aimed at 
enhancing the screening of visa-exempt third-country nationals entering its territory. 

2.  Monitoring  trends  in  illegal  migration,  applications  for  international  protection, 

returns and readmission  

In 2024, the number of applications for international protection in Member States by nationals 
of  North Macedonia decreased by 50%, with 3,435 applications lodged in 2024 compared with 
6,890 in 2023. The recognition rate remained the same: 1%. 

In 2024, the number of nationals of North Macedonia found to be illegally staying decreased with 
6,785  illegal  stays  in  2024  (7,470  in  2023).  The  number  of  refusals  of  entry  increased,  (2,575 
refusals in 2023, 2,850 in 2024). 

The number of return decisions issued to nationals of North Macedonia decreased by 15% (2,600 
in 2024, 3,045 in 2023). The number of persons returned increased by 27% (2,485 in 2024, 1,965 
in  2023).  Member  States  reported  good  cooperation  on  return  and  readmission;  the  return  rate 
increased in 2024 (96% compared with 65% in 2023). 

8  

In decreasing order from the highest to the lowest number of citizenships. 

26 

 
 
 
 
Member States reported approximately 2,700 refusals of entry in 2024 - a 13% increase compared 
to  2023.  In  2024  5,072  nationals  of  North  Macedonia  were 
illegally 
staying/overstaying in the Schengen area, a figure that is similar to that from 2023.  

identified  as 

Source: Eurostat 

3.  Cooperation on migration, border management and readmission  

The implementation of the Status Agreement with Frontex continues without difficulties, notably 
through the activity of the Frontex Joint Operation (JO) North Macedonia 2024. In the area of 
border management, the application of Frontex training standards is ongoing.  

Cooperation on readmission in 2024 was generally satisfactory, with Member States reporting 
smooth  implementation  of  the  relevant  agreements.  North  Macedonia  needs  to  improve  its 
cooperation  with  countries  of  origin,  especially  because  occasional  delays  in  processing 
readmission requests were reported. In the area of asylum, the Asylum Sector, in cooperation 
with  the  European  Union  Agency  for  Asylum  (EUAA),  has  developed  a  third  Roadmap  for 
Cooperation 2025–2027, replacing the previous one. Staff from the Asylum Sector continue to 
participate in EUAA training programmes on asylum and refugee law. However, the quality of 
asylum procedures remains a concern. 

4.  Cooperation on security 

In  2024,  North  Macedonia  continued  cooperation  with  Europol.  In  February  2025,  a  Joint 
Investigation Team (JIT) comprising North Macedonia, Serbia, Europol, and Eurojust successfully 
dismantled an organised criminal group involved in counterfeiting currency, primarily euros. Over 
the course of 2024, North Macedonia also participated in two additional JITs focused on currency 
counterfeiting.  Between  2024  and  2025,  North  Macedonia  has  participated  in  94  Operational 
Actions, structured across 14 Operational Action Plans, acting as Co-Leader in six. A National 
EMPACT  Coordinator  and  Deputy  were  appointed  in  May  2022,  and  a  new  Deputy  National 
Coordinator was appointed in 2025. Use of CT-SIENA (for counter-terrorism purposes) increased 

27 

 
 
 
substantially  in  2024—North  Macedonia’s  second  year  of  usage—  with  4,520  messages 
exchanged, compared to 759 in the previous year. 

North Macedonia remained engaged in the implementation of the Joint Action Plan on Counter 
Terrorism for the Western Balkans and in discussions on the preparation of the new Joint Action 
Plan that was signed in October 2025.  

5. 

Investor citizenship schemes  

The Law on Citizenship of North Macedonia allows the acquisition of citizenship without prior 
residence requirements for individuals deemed to represent a ‘special economic interest’ for the 
country.  No  amendments  to  this  legal  provision  were  adopted  in  2024.  During  2024,  three 
applications for citizenship by citizens of Türkiye were submitted; two resulted in the granting of 
citizenship. Of the five applications submitted in 2023, one led to the granting of the citizenship 
to the applicant (from Bosnia and Herzegovina); four are still under assessment. 

The Commission reiterates that the implementation of this provision should not result in the 
systematic granting of citizenship in exchange for investment. If misused, this scheme could 
negatively impact the integrity of the visa-free regime. 

SERBIA 

1.  Visa policy alignment 

Since October 2022 Serbia progressed regularly towards more visa policy alignment with EU. In 
December 2024 Serbia introduced a visa regime for nationals of  Kuwait, Mongolia, Oman and 
Qatar  ,  fulfilling  its  commitments  in  this  policy  area  under  its  Reform  Agenda  within  the 
framework of the Growth Plan for the Western Balkans. Despite this progress, Serbia currently 
maintains  a  visa-free  regime  with  12  countries  which  are  visa-required  in  EU:  Armenia, 
Azerbaijan,  Bahrain,  Belarus,  China,  Indonesia,  Jamaica,  Kazakhstan,  Kyrgyzstan,  Russia, 
Suriname, and Türkiye. In November 2023, Serbia adopted a Plan for the Harmonization of the 
Visa Regime with EU Policy, which states that full alignment with the EU list will take place six 
to  twelve  months  prior  to  Serbia’s  EU  accession.  However,  this  plan  does  not  meet  the  EU 
expectations.  

Several EU Member States and Frontex have identified visa-free access to Serbia for third-country 
nationals—especially from Türkiye, China, and Russia—as contributing to illegal migration flows 
to the EU. As such, the Commission urges Serbia to accelerate its efforts toward full alignment as 
a matter of priority. 

Pending full alignment, Serbia is urged to implement robust screening procedures for visa-
exempt  third-country  nationals,  particularly  those  originating  from  countries  presenting 
heightened security or illegal migration risks. 

28 

 
 
   
 
In May 2025, Serbia launched a new digital platform for travel authorisations as a pilot phase in 
the digitalisation of its visa application and approval procedures. The platform currently covers 42 
countries which are visa required for Serbia, of which 26 are also visa-required in the EU, therefore 
Serbia  should  ensure  appropriate  safeguards  and  security  checks  when  processing  the  travel 
authorisations from these countries. At this stage, digitalisation applies exclusively to tourist visas 
and short-term stays. 

2.  Monitoring  trends  in  illegal  migration,  applications  for  international  protection, 

returns and readmission 

In 2024, 3,270 applications for international protection were submitted by Serbian nationals in 
Member States, a decrease of 30% compared to 2023 (4 695). The recognition rate remained stable 
with 2% in 2023 and in 2024. 

The number of illegal borders crossings into the EU by Serbian nationals remained marginal 
(21 in 2023, 35 in 2024). The number of Serbian nationals found to be staying illegally in Member 
States  continued  to  decrease  (12,700  people  in  2024,  13,500  in  2023).  On  the  other  hand,  the 
number of Serbian nationals refused entry increased (5,800 in 2023, 6,305 in 2024). 

In 2024, approximately 1,900 illegal border crossings by third-country nationals from Serbia to 
the EU were recorded, mainly occurring at the Hungarian border. This represents a 96% decrease 
compared to 2023, when about 84,100 such crossings were registered. 

The number of return decisions issued to Serbian nationals rose slightly from 6,030 in 2023 to 
6,140  in  2024.  The  number  of  people  returned  increased  (3,610  in  2024  compared  to  3,415  in 
2023) and the return rate increased from 57% in 2023 to 59% in 2024.  

Source:Eurostat 

29 

 
 
 
 
 
   
3.  Cooperation on migration, border management and readmission 

Serbia  continued  to  implement  the  EU  Action  Plan  on  the  Western  Balkans,  the  Integrated 
Border Management Strategy 2022–2027 and the corresponding Action Plan 2022–2024. During 
2023 and 2024, Serbia intensified actions to strengthen border security and dismantle migrant 
smuggling  networks.  However,  illegal  migration  towards  the  EU  via  Serbian  territory 
persisted, and Serbia remained a key transit country where migrant smuggling groups continued 
to operate with notable intensity and violence.  

In 2024 and 2025, a growing concern emerged regarding illegal migrants arriving in the EU or 
Schengen states, who had first entered Serbia legally, often holding short- or long-term visas 
or work permits. It highlightsvulnerabilities in Serbia’s visa issuance and migration control 
systems. 

Serbia continued its operational cooperation with Frontex.  In June 2024, Serbia and the EU 
signed  a  Second-Generation  Status  Agreement,  which  entered  into  force  on  1  April  2025, 
replacing the earlier framework and allowing the enhanced deployment of Frontex officers. Serbia 
maintained  its  cooperation  with  the  European  Union  Agency  for  Asylum  (EUAA),  based  on 
successive bilateral roadmaps. Serbia also pursued bilateral and multilateral partnerships with 
EU  Member  States  in  migration  and  border  management,  receiving  technical  assistance, 
equipment and training, sharing information and risk analysis, conducting joint border patrols, 
etc.  

On  readmission,  Frontex  and  Member  States  generally  reported  good  cooperation  with  Serbia. 
Delays in issuing return travel documents were noted in 2024, but the situation improved in 2025. 
However, concerns persist over Serbia’s practice of conditioning the issuance of return documents 
on the prior submission of a flight plan. 

A further longstanding issue concerns Serbia’s limited cooperation on the readmission of third-
country nationals who transited through its territory, including in cases where credible proof of 
transit exists (e.g. identity documents issued by Serbia to asylum seekers). This practice remains a 
matter of concern for the Commission. 

Regarding the return of Third Country Nationals to their countries of origin, Serbia returned 101 
persons voluntarily with EU support in 2024, mainly to Türkiye, India, Morocco, Armenia and the 
Russian Federation. This marks an increase of 13% in comparison to 2023 (89). 

4.  Cooperation on security 

In  2024,  Serbia  continued  its  close  cooperation  with  Europol,  particularly  in  the  fields  of 
organised  crime  and  counterterrorism  through  Joint  Investigation  Teams  (JITs)  and 
multinational  task  forces,  dismantling  criminal  networks  engaged  in  migrant  smuggling  and 
trafficking  in  human  beings.  A  Serbian  Liaison  Officer  is  stationed  at  Europol  headquarters, 
facilitating operational cooperation with EU Member States.  

Serbia  also  remained  an  active  participant  in  the  EMPACT  framework,  supporting  multiple 
priority  crime  areas.    Cooperation  with  CEPOL  intensified  further  in  2024,  with  Serbian  law 
enforcement personnel participating in training sessions and staff exchange programmes. Close 

30 

 
 
 
collaboration continued with Eurojust, particularly through the Serbian Liaison Prosecutor. Serbia 
also contributed to Joint Investigation Teams supported by Eurojust in complex cross-border cases. 

Serbia maintained security cooperation with neighbouring EU Member States - notably Croatia 
and Romania - in combating serious cross-border crimes, including the smuggling of migrants, 
narcotics and firearms.  

Criminal networks based in Serbia engaged in the large-scale production of counterfeit and forged 
identity documents, including Serbian but also a wide range of those issued by EU Member States. 
The  scale  and  sophistication  of  these  forgeries  are  alarming,  including  high-quality  e-passport 
counterfeits capable of circumventing modern document verification systems. 

The possibility for Serbian nationals expelled from the EU to change their identity and obtain new 
official  documents  under  a  different  name  continues  to  present  a  systemic  vulnerability.  This 
practice allows undetected re-entry into the EU, undermining the integrity of return procedures 
and border controls. 

Serbia remained engaged in the implementation of the Joint Action Plan on Counter Terrorism for 
the Western Balkans and in discussions on the preparation of the new Joint Action Plan that was 
signed  on  30  October.  2025.  The  Strategy  on  counter  terrorism  and  prevention  of  violent 
extremism expired in 2022, and the new strategy has not yet been adopted. 

5. 

Fast-track acquisition of Serbian citizenship    

It  has  been  established  that  since  2022,  over  200  Russian  nationals  have  obtained  Serbian 
citizenship under Article 19 of the Law on Citizenship, which allows for the granting of citizenship 
“in the interest of the Republic of Serbia.” This provision permits the acquisition of citizenship 
without any prior mandatory residence in Serbia and without requiring applicants to renounce their 
existing citizenship(s). 

Granting  of  Serbian  citizenship  to  Russian  nationals  outside  the  regular  naturalisation  process 
might enable circumvention of the Schengen visa regime and the security checks it entails. The 
profiles of several individuals who have acquired citizenship in this manner have raised alarm on 
the  EU  side.  These  developments  warrant  further  scrutiny  to  assess  whether  this  practice  is 
abusive.  

UKRAINE 

1.  Visa policy alignment 

Ukraine’s  visa  policy  is  not  aligned  with  the  EU  as  it  maintains  a  visa-free  regime  with  15 
countries that are on the EU list of visa-required countries (Armenia, Azerbaijan, Bahrain, 
Belarus,  Ecuador,  Kazakhstan,  Kuwait,  Kyrgyzstan,  Mongolia,  Oman,  Qatar,  Saudi  Arabia, 
Tajikistan, Türkiye, and Uzbekistan). 

There was no progress towards more alignment with the EU list of visa-required countries in 2024. 

31 

 
 
 
2.  Monitoring trends in illegal migration, applications for international protection, returns 

and readmission  

Following the activation of the Temporary Protection Directive in 2022, as of 30 April 2025 the 
estimated  number  of  active  registrations  for  temporary  protection  in  the  27  Member  States, 
Norway,  Liechtenstein,  Iceland  and  Switzerland,  according  to  Eurostat,  is  4,415,585  of  which 
4,261,805 in the EU Member States.  

In 2024, the number of Ukrainian applicants for international protection in Member States was 
28,350, 76 % more than in 2023 (16,105). The recognition rate was 88% in 2023 and 81% in 2024. 

The number of Ukrainian nationals illegally crossing the EU border in 2024 increased by 217% 
(14,503 in 2024 compared with 4,579 in 2023). In 2024, 44,530 Ukrainian nationals were found 
to be illegally staying in EU (40,950 in 2023, an increase of 9%). The number of refusals of entry 
to Ukrainian nationals rose by 7%, from 18,260 in 2023 to 19,520 in 2024. 

The number of return decisions issued to Ukraine nationals rose by 15% (8,730 in 2024 compared 
to 7,610 in 2023). The number of people returned decreased by 6% (1,170 in 2024 compared to 
1,245 in 2023) and the return rate decreased from 16% in 2023 to 13% in 2024. 

Source:Eurostat 

3.  Cooperation on migration, border management and readmission 

Since the start of Russia’s war of aggression in 2022, a large number of Ukrainian nationals have 
fled  to  EU  Member  States,  prompting  the  activation  of  the  EU’s  Temporary  Protection 
Directive. 2024 saw an increase in the number of Ukrainian citizens illegally crossing EU borders, 
overstaying in the Schengen area, or applying for asylum. A significant portion of these  illegal 

32 

 
 
 
 
crossings  has  been  motivated  by  conscription  avoidance.  The  use  of  forged  or  fraudulent 
documents has become increasingly frequent among illegal Ukrainian migrants. 

The last non-biometric Ukrainian passports were issued in 2016 and are expected to be fully phased 
out  by 2026. The number of such passports  still in  circulation  is  currently marginal. However, 
concerns  have  been  raised  regarding  Ukrainian  nationals  possessing  multiple  valid  biometric 
passports. This can allow individuals to manipulate the 90/180-day visa-free rule in the Schengen 
area by alternating travel documents. There have also been instances of manually altered passport 
expiry dates—raising concerns about the validity and integrity of such renewals. 

Despite  the  ongoing  war,  Ukraine’s  migration  and  border  management  systems  remain 
operational  in  government-controlled  areas.  In  2024,  Ukrainian  migration  and  border 
authorities maintained active cooperation with a wide range of international partners, including the 
EU Agency for Asylum (EUAA), the Delegation of the European Union to Ukraine, the European 
Union Advisory Mission (EUAM), Frontex, the International Organization for Migration (IOM), 
the UN High Commissioner for Refugees (UNHCR), and the International Centre for Migration 
Policy Development (ICMPD). 

As a result of the prolonged Russian aggression, Ukraine's institutional needs remain substantial. 
EU and Member States have continued to provide support to Ukraine’s border services through 
the provision of training and material assistance, including drones, armoured vehicles, engineering 
and surveillance equipment, and other specialised technology. 

Ukraine  has  remained  active  in  combating  trafficking  in  human  beings,  including  by 
continuing the implementation of the Common Anti-Trafficking Plan.  

Although war conditions have reduced the flow of illegal migrants through and towards Ukraine, 
in 2024, border guards and immigration services intercepted 8,227 foreign nationals for offences 
such as illegal border crossing, illegal residence, or visa overstays (compared to 8,856 in 2023). 
Approximately 40% of detected illegal migrants were citizens of Moldova, Azerbaijan, and Russia. 

Ukraine continues to examine and grant international protection. As of 2024, there were 1,301 
recognised refugees in Ukraine and 1,095 beneficiaries of subsidiary protection. 

While many EU Member States suspended the return of Ukrainian nationals following the 2022 
invasion, limited cooperation on readmission has continued with others.  For cases in which returns 
were carried out,  Member States reported overall  good cooperation  with  Ukrainian  authorities, 
although  administrative  procedures  were  occasionally  delayed  due  to  the  difficult  operating 
conditions created by the war. 

4.  Cooperation on security 

In 2024, Ukrainian law enforcement authorities continued cooperation with EU agencies, Member 
States, and international organisations in the field of security. Cooperation with Europol remained 
particularly  strong  in  counter-terrorism  efforts,  as  well  as  the  fight  against  the  trafficking  of 
firearms,  explosives,  and  CBRN  materials,  trafficking  in  human  beings,  financial  crime,  and 
cybercrime.  Ukraine  also  cooperated  closely  with  Europol  and  Eurojust,  including  in  the 
investigation of war crimes committed by the Russian armed forces on Ukrainian territory. 

33 

 
 
Eurojust  continued  to  support  the  Joint  Investigation  Team  (JIT)  established  between  six  EU 
Member  States,  Ukraine,  and  the  Office  of  the  Prosecutor  of  the  International  Criminal  Court 
(ICC). CEPOL provided capacity-building support to Ukrainian law enforcement, training 1,400 
police officers over the course of 2024. The Asset Recovery and Management Agency (ARMA)—
Ukraine’s  central  authority  for  identifying,  tracing,  and  managing  assets  from  criminal 
proceedings—intensified its cooperation with Europol to recover assets concealed by criminals in 
several EU Member States. 

In the fight against organised crime, Ukraine participated in the implementation of Operational 
Action Plans (OAPs) under the EMPACT framework for the 2022–2025 cycle. The fight against 
illicit firearms trafficking remains a shared priority between Ukraine and EU Member States. In 
February 2025, Ukraine established a Coordination Centre for Combating the Illegal Trafficking 
in Firearms, bringing together representatives from the national police, border guard, and military 
services.  In  December  2024,  the  Working  Arrangement  between  Ukraine  and  the  EU  Drugs 
Agency (EUDA) was renewed.  

As part of the implementation  of Ukraine’s  Anti-Corruption  Strategy 2021–2025  and the  State 
Anti-Corruption  Programme  2023–2025,  steps  were  taken  to  enhance  the  independence  of  the 
Specialised Anti-Corruption Prosecutor’s Office (SAPO), increase staffing for the National Anti-
Corruption Bureau of Ukraine (NABU), and introduce single-judge criminal proceedings in the 
High Anti-Corruption Court (HACC) as the court of first instance for relevant cases. 

34 

 
 
II.  EASTERN CARRIBEAN  

Since  2020,  the  Commission  has  been  engaging  with  the  five  visa-free  Eastern  Caribbean 
countries operating investor citizenship schemes—Antigua and Barbuda, Dominica, Grenada, 
Saint Kitts and Nevis, and Saint Lucia—to obtain detailed information and data on the operation 
of these schemes. 

All  five  countries  run  distinct  investor  citizenship  schemes  which  generally  involve  foreign 
nationals  making  direct  contributions  to  the  state  budget  or  investing  in  major  infrastructure, 
utility, or real estate projects in exchange for citizenship. 

The application process and the due diligence and security screening procedures used across the 
five Eastern Caribbean countries  operating investor citizenship schemes are broadly  similar.  In 
March 2024, the governments of the five countries operating  investor citizenship schemes have 
signed  a  Memorandum  of  Agreement  as  a  joint  commitment  to  harmonize  the  minimum 
investment  threshold  to  USD  200,000,  enhance  the  cooperation  on  due  diligence,  strengthen 
security screening procedures, establish common information-sharing and transparency standards, 
create a regional competent authority to enforce international standards, regulate authorised agents 
and  marketing  practices,  develop  joint  training  and  capacity-building  initiatives  and  set  out 
mechanisms for dispute resolution. 

In parallel to the Memorandum of Agreement, six core principles for the governance of investor 
citizenship schemes were agreed in February 2023 between the five Eastern Caribbean countries 
operating such schemes and the United States Department of the Treasury. They include the mutual 
recognition  of  and  cooperation  on  application  denials,  mandatory  interviews  with  applicants 
(which may be conducted virtually), additional due diligence by national Financial Intelligence 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Units, annual independent audits of schemes, retrieval of passports that have been revoked and the 
suspension of applications from nationals of certain designated countries. It must be noted that the 
concerns raised by the U.S. Department of Treasury relate to Anti-Money Laundering policy, not 
to visa policy. 

In August 2025, the five Caribbean countries jointly notified the Commission of the establishment 
of  a  regional  regulator  for  the  operation  of  investor  citizenship  schemes.  The  five  Caribbean 
countries  described  the  key  provisions  of  the  legislation  as  follows:  funding  of  the  schemes 
regulator, enforcement mechanisms for compliance, collection of biometrics of new applicants, 
residency requirement for approved applicants and financial support for CARICOM JRCC.   

Since  the  publication  of  the  Seventh  VSM  Report,  the  total  number  of    investor  citizenship 
schemes  applications  across  the  five  countries,  has  remained  substantial  (13,113  in  2023, 
10,573 in 2024). In Saint Kitts and Nevis, the volume of applications went from 1,987 in 2023 to 
223  in  2024  and  in  Grenada  from  2,297  to  420  applications.  Application  numbers  remained 
relatively  stable  in  Dominica  and  Saint  Lucia,  while  Antigua  and  Barbuda  recorded  a  notable 
increase, from 685 in 2023 to 1,733 in 2024. 

To  date,  an  estimated  107,625  passports  have  been  issued  across  the  five  Eastern  Caribbean 
investor  citizenship  schemes  operating  countries.  At  the  same  time,  in  2024  rejection  rates 
remained low:  1.7% in Antigua and Barbuda, 5.3% in Saint Lucia, and 6.5% in Dominica. 
These figures, considered alongside the short statutory processing times, raise concerns about 
the adequacy of the security and due diligence procedures applied. 

The  table  below  presents  the  most  recent  and,  in  some  cases,  partial  data  submitted  to  the 
Commission  by  the  five  countries.  Applications  may  include  several  members  of  a  family, 
explaining why the number of applications can be lower than the number of passports issued to 
each family member in case of a successful application. 

Antigua and 
Barbuda  

Dominica   

Grenada  

Saint Kitts and 
Nevis  

Saint Lucia  

Total 
applications 
received   

4 332 (2015-2023)  

13 161 (2015-
2022)  

5 847 (2015-
2023)  

19 655 (2015-
2023)  

7 437 (2015-
2023)  

1 733 (2024)  

78 (2025 until 
30/4)  

4 068 in 2023  

420 (2024)  

223 (2024)  

4 304 (2024)  

3 893 in 2024  

123 (2025 until 
31/03)  

171 (2025 until 
30/4)  

120 (2025 
until 30/4)   

Rejections  

169 (2015-2023)  

30 (2024)  

5 (2025 until 30/4)  

420 (2019-
2022)  

210 (2023)  

255 (2024)  

256 (2015-2023)  

739 (2015-2023)  

93 (2024)  

98 (2024)  

25 (2025 until 
31/03)  

86 (2025 until 
30/4)  

97 (2015-
2023)  

227 (2024)  

151 (2025 
until 30/4)  

36 

 
 
   
Rejection 
rate  

(2024)  

Total 
passports 
issued  

1.7%  

6.5%   

22.1%  

43.9%  

5.3%  

7 995  

29 590  

(2015-2023)  

(2018-2021)  

1 276 (2024)  

9 539 (2023)  

(2025  until 

9 586 (2024)  

540 
30/4)  

16  086  (2015-
2023)  

48  844  (2015-
2023)  

N/A  

5 180 (2024)  

6 437 (2024)  

1 518 (2025 until 
31/03)  

734 (2025  until 
30/4)  

In 2024, among the four Eastern Caribbean countries that reported data on the main nationalities 
of successful applicants (Saint Kitts and Nevis, Dominica, Saint Lucia, and Antigua and Barbuda) 
the  majority  of  applicants  continued  to  originate  from  countries  that  are  subject  to  visa 
requirements for entry into the EU. Notably, successful applicants included 531 nationals of Syria, 
365 of Iraq, and 333 of China. In Grenada, which also reported partial data, the leading applicant 
nationalities in 2024 were China (96 applicants) and Nigeria (82 applicants). 

All  five  countries  apply  a  restricted  countries  policy,  under  which  individuals  holding  certain 
nationalities are excluded from applying to their investor citizenship schemes. 

These countries include:  

- 

- 

- 

- 

- 

In Grenada: Afghanistan, Belarus, Iran, North Korea, Sudan, Russia, Yemen 

In Antigua and Barbuda: Russia, Belarus, Afghanistan, Iran, North Korea, Sudan, Yemen 
and Somalia 

In Saint Lucia: Russia, Belarus, Iran, Cuba, Venezuela, North Korea 

In Saint Kitts and Nevis: Russia, Belarus, Iran, Iraq, North Korea, Afghanistan 

In Dominica: Russia, Belarus, Iraq (Northern part), Yemen and unless certain criteria met 
North Korea and Sudan 

Investor citizenship schemes inherently carry security risks for the Schengen area. No such 
scheme can be considered risk-free from a security and migration control perspective and obtaining 
visa-free access to the EU continues to be a major benefit for beneficiaries of investor citizenship 
schemes that would be otherwise visa-required. 

37 

 
 
  
 
 
 
 
III.  LATIN AMERICA  

Unfounded  asylum  applications  lodged  by  visa-exempt  third-country  nationals  continue  to 
pose  a  significant  challenge  for  EU  Member  States.  These  applications  have  low  recognition 
rates, placing a disproportionate burden on national asylum systems. Between 2015 and the first 
quarter of 2025, 18% of all asylum applications received in EU were lodged by nationals from 
countries benefiting from visa-free access to the EU. 

A substantial share of these claims originates from Latin America.  Between 2015 and Q1 
2025, nationals of Latin American countries with visa-free access to the EU lodged over 50% of 
all asylum claims submitted by visa-exempt third-country nationals during this period. 

In  2024,  a  total  of  166,910  asylum  applications  were  lodged  by  nationals  of  the  fifteen  Latin 
American countries with visa-free access to the EU, compared to 172,770 in 2023—a decrease of 
approximately 3% year-on-year. While asylum requests have been recorded from nationals of all 
fifteen visa-exempt countries in the region, the highest numbers are observed among nationals 
of  Venezuela,  Colombia,  and  Peru.  These  are  followed,  at  lower  levels,  by  Honduras, 
Nicaragua, and El Salvador. The remaining countries in the region currently account for lower 
numbers of applications. 

38 

 
 
 
 
 
Asylum applications 2023 compared to 2024

74015

69520

51615

63295

27260

23275

Venezuela

Colombia

Peru

Honduras

Nicaragua

El Salvador

Others

2380

4065

2475
3340

2575
3060

6590
6215

0

10000

20000

30000

40000

50000

60000

70000

80000

2024

2023

Source: Eurostat 

As  regards  Venezuela,  the  number  of  applications  for  international  protection  lodged  by 
Venezuelan nationals in EU Member States has shown a consistent upward trend over the past 
three years, with annual figures exceeding 50,000. In 2024, a total of 74,015 applications were 
submitted, compared to 69,520 in 2023. 

The  Commission  recognises  that  this  increase  is  closely  linked  to  the  ongoing  political  and 
economic crisis in Venezuela.  The majority of Venezualians obtain a national residence permit 
on humanitarian grounds in one of the Member States after the completion of the international 
protection procedure. The Commission reaffirms the EU’s commitment to supporting a peaceful, 
democratic,  and  inclusive  Venezuelan-led  solution  to  the  crisis,  in  coordination  with  its 
international and regional partners. Nevertheless,  the steady increase of asylum applications by 
Venezuelan nationals in the EU on the 2015-2025 period, combined with the low recognition rate 
constitute a reason for concern. 

Relations with Venezuela remain strained, due to persistent and serious concerns regarding the 
state of democracy and human rights. Currently, there are no accredited Ambassadors between 
the EU and Venezuela in Brussels and Caracas, and no structured dialogue is in place.  

As regards Colombia, in 2024, Colombian nationals lodged 51,615 applications for international 
protection in EU Member States—a 19% decrease compared to 2023 (63,295 applications). The 
Commission acknowledges that these trends are partly linked to Colombia’s role as a host country 
for nearly 3 million refugees and migrants from Venezuela, which places considerable pressure on 
its social and economic systems. As reaffirmed in the Joint Communication, the EU will continue 
to support Colombia and the broader region in responding to this migration crisis and in managing 
the humanitarian, social, and institutional challenges it entails. 

39 

 
 
 
 
The  Commission  services,  in  cooperation  with  the  European  External  Action  Service  (EEAS), 
have  engaged  in  dialogue  with  Colombia  in  the  context  of  growing  concerns  over  unfounded 
asylum  applications.  This  engagement  has  taken  place  through  the  technical  EU–Colombia 
Roundtable  on  Migration  and  Mobility,  held  on  12  November  2024,  and  the  EU–Colombia 
Political Dialogue of 26 June 2025. The issue of unfounded asylum applications has also been 
raised  in  several  high-level  meetings  between  the  Commission  and  Colombian  counterparts  at 
senior  official  and  ministerial  levels.  In  response,  Colombia  expressed  its  readiness  to  take 
concrete actions. As part of this commitment, a communication campaign was launched in April 
2025 to raise awareness among potential migrants regarding the conditions of visa-free travel and 
asylum  eligibility.  Following  those  dialogues,  a  significant  decrease  —close  to  50%—  in 
international protection applications has been observed in 2025.  

As regards Peru, there was a sharp increase of 17% in the number of applications for international 
protection lodged in Member States between 2023 and 2024, with 27,260 applications submitted 
in 2024 compared with 23,275 in 2023. This issue has been discussed at the end of 2025 in high-
level  meeting  with  the  Peruvian  authorities.  The  Peruvian  authorities  expressed  readiness  to 
address it.  

As  regards  Honduras,  in  2024  there  were  2,380  applications  for  international  protection  in 
Member States, compared to 4,065 in 2023, representing a decrease of 42%. 

As  regards  Nicaragua,  in  2024  there  were  2,475  applications  for  international  protection  in 
Member States, compared to 3,340 in 2023, representing a decrease of 26%. 

As  regards  El  Salvador,  in  2024  there  were  2,575  applications  for  international  protection  in 
Member States, compared to 3,060 in 2023, representing a decrease of 16%. 

Following  those  dialogues,  a  significant  decrease  —close  to  50%—  in  international  protection 
applications has been observed in 2025. To ensure the sustainability of visa exemptions, visa-free 
travel must remain strictly limited to short stays. In this context, the Commission services—
working closely with the EEAS—will continue to engage with the most affected countries in the 
region, including by exchange of information and best practices, support to national authorities in 
the implementation – when possible - of effective border control measures at departure points, 
launching of awareness-raising campaigns on the rights and obligations under visa-free regimes 
and promotion of other relevant actions to address the  issue of abuse of visa free regime, resulting 
in high numbers of asylum applications and illegal stays. 

In parallel, and with regard to longer stays, parties are encouraged to strengthen cooperation on 
legal pathways and develop mutually beneficial mobility arrangements, as outlined in the Joint 
Communication:  A  New  Agenda  for  Relations  between  the  EU  and  Latin  America  and  the 
Caribbean. 

40