Médecins du Monde and PICUM raise concerns over European Commission proposal for a common return system
In March 2025, the European Commission proposed a regulation establishing a common return system for third-country nationals staying illegally in the EU. Médecins du Monde and PICUM have published a report highlighting potential risks associated with the proposal, particularly concerning access to healthcare and data protection. The report outlines how the proposal may affect the rights of individuals, including vulnerable groups, and raises ethical concerns for professionals. The organisations call on EU lawmakers to ensure that the regulation respects fundamental rights and medical ethics.
The European Commission published the proposal for a regulation establishing a common return system in March 2025. Médecins du Monde and PICUM have now expressed concerns regarding its potential impact on health, privacy, and professional ethics.
Key concerns identified by the organisations include:
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Concerns regarding detection measures: The report highlights, among other points, that detection measures will increase fear of immigration enforcement among undocumented people, discouraging them from seeking help from public services, especially healthcare. It also warns that in some cases, detection measures take the form of proactive reporting obligations, which may put healthcare professionals in conflict between their duty of care and obligations to report, threatening professional integrity and trust with service users.
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Concerns regarding immigration detention: The report draws attention to evidence showing that immigration detention causes significant mental and physical health deterioration, particularly for already vulnerable individuals. It also underlines that any provision allowing for the detention of children violates the best interests of the child principle and contradicts international child rights standards.
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Concerns regarding removal procedures and operations: The report draws attention to the introduction of coercive measures that can cause severe physical and psychological harm, particularly for vulnerable individuals. It highlights that medical needs are not consistently considered when extending voluntary departure periods or postponing deportations, which can lead to interruptions or discontinuity of healthcare, including in offshore deportation centres.
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Concerns regarding data sharing and health data: The report underlines that health data are highly sensitive and protected under EU and international law, yet the proposal does not consistently guarantee informed consent for medical examinations or data sharing. It stresses that breaches of medical confidentiality risk undermining individual rights, trust in healthcare, and the ability to deliver effective medical care.
For further details, please read the press release of Medecins du Monde in French or in Dutch, including a link to the report itself.