On 11 March 2025, the European Commission presented a proposal for a new Return Regulation, intended to replace the current Return Directive. The proposal aims at "increasing the efficiency of the return process by providing Member States with clear, modern, simplified and common rules for managing returns effectively". It, inter alia, introduces measures covering detention, monitoring, obligations for individuals subject to return orders, and data sharing.

While this proposal is being discussed within the relevant EU Council working groups, more than 200 organisations have expressed their concerns in a joint statement dated 15 September 2025. The statement sets out nine key concerns:

• The proposal permits returns to non-EU countries with which individuals have no prior connection and the establishment of offshore “return hubs”, which could lead to arbitrary detention and limited access to procedural safeguards.
   

• It requires States to identify and monitor people staying irregularly, potentially increasing discriminatory practices and affecting access to healthcare, social services, and legal protections.
   

• Return orders would be issued automatically, limiting consideration of other residence options and increasing the number of people in irregular situations.
   

• Grounds and maximum duration for detention would be extended, including for children and vulnerable groups, while safeguards could be weakened.
   

• Obligations linked to compliance with return procedures, coupled with sanctions for non-compliance, may disproportionately affect people in vulnerable circumstances.
   

• Appeal rights are limited, as the automatic suspensive effect of appeals is removed and deadlines shortened, reducing the ability to effectively challenge return decisions.
   

• Digital data collection, storage, and sharing, including sensitive personal information, are expanded, raising potential privacy and protection concerns.
   

• The proposal was issued without a formal human rights impact assessment or broad consultation.
   

• It prioritises returns over alternative pathways to legal residence, such as humanitarian, family, or child-based permits, increasing legal uncertainty and undermining protection and inclusion.

Civil society organisations call on the European Commission to withdraw the proposal and urge the European Parliament and Council to reject it in its current form.

For additional information, please read the statement attached below.