Raphael Bossong, Anne Koch and Zefitret Abera Molla

Return Hubs in European Migration Policy

A Residual Instrument with Systemic Risks

SWP Comment 2026/C36, August 2026

Impressum

This work is licensed under CC BY 4.0

This Comment reflects the authors’ views.

SWP Comments are subject to internal peer review, fact-checking and copy-editing. For further information on our quality control procedures, please visit the SWP website: https://www.swp-berlin.org/en/about-swp/ quality-management-for-swp-publications/

SWP

Stiftung Wissenschaft und Politik

German Institute for International and Security Affairs

Ludwigkirchplatz 3–4
10719 Berlin
Telephone +49 30 880 07-0
Fax +49 30 880 07-100
www.swp-berlin.org
swp@swp-berlin.org

ISSN (Print) 1861-1761

ISSN (Online) 2747-5107

DOI: 10.18449/2026C36

The EU Return Regulation creates a legal basis for transferring individuals subject to enforceable return decisions to third countries willing to accept them, even where they have no prior connection to that country. This makes so-called return hubs an increasingly likely prospect. The political appeal is clear: return hubs offer governments a visible way to demonstrate enforcement at a moment when the EU Pact on Migration and Asylum depends on credible implementation. But political salience should not be mistaken for operational effectiveness. European precedents and recent US experience suggest that transfers to remote third countries are likely to remain marginal, expensive and dependent on tenuous bargains. Return hubs may play a limited role for a small group of people who are otherwise difficult or impossible to remove, but they are not a general solution to low return rates. Their value should be judged by their ability to produce sustainable outcomes that cannot be achieved through the core return system. Without strict tests of additionality, proportionality and rights protection, they may make the wider return system harder, not easier, to fix.

Return Hubs in European Migration Policy

A Residual Instrument with Systemic Risks

Raphael Bossong, Anne Koch and Zefitret Abera Molla

Return policy has become a central concern of European migration politics. Growing political pressure, especially from far-right and populist parties, has made enforcement of return decisions a test of state capacity and political credibility, and a barometer of public confidence. EU institutions put the effective return rate at around 20 to 30 per cent, although this ratio is difficult to interpret because return decisions and departures concern different cohorts, some departures go unrecorded, and the same person may be subject to return decisions in more than one member state. Return rates also vary widely by country of origin. More generally, return policy faces persistent structural obstacles, so promises of rapid and dramatic improvements should be treated with scepticism.

Since the EU Pact on Migration and Asylum came into effect on 12 June 2026, the political stakes attached to effective returns have risen further. The Pact links rejection in the asylum border procedure to a return border procedure of no more than twelve weeks. Whether member states are able to complete removals within that period will be one of the earliest and most closely watched tests of the Pact’s implementation. If they cannot, the case passes into the general return system.

The core components of the EU return system (hereinafter “the core return system”) are identification, documentation and consular cooperation, direct voluntary or forced return, readmission cooperation with countries of origin, and reintegration support. All these aspects and phases present challenges that cannot be sidestepped by outsourcing them to third countries.

A reform of the 2008 EU Return Directive, which governs the wider return system, was excluded from the already highly complex package agreed in 2024 to overhaul the Common European Asylum System. A sharp rightward shift in the composition of the European Parliament subsequently led to the prioritisation and swift agreement on a new EU Return Regulation, which is in the final stages of adoption. In the current political context, the new Return Regulation has been presented as the “missing piece” required to complete the Pact on Migration and Asylum and restore control over irregular migration, but it remains normatively contested. Among other aspects, it strengthens mutual recognition of return decisions among member states, creates a standard European Return Order in the Schengen Information System, expands the duties of persons subject to return procedures to cooperate, and extends the maximum period of detention.

Article 17 of the new Regulation has attracted particular attention. It permits member states to designate as the country of return a third country that has agreed, under an EU-level, multilateral or bilateral arrangement, to accept persons subject to enforceable return decisions. Crucially, this may apply even where a person has no prior connection – by nationality, residence or transit – to the third country. That is the legal precondition for so-called return hubs. Under the Regulation, the removal process is complete once a person has arrived in the designated third country. Although the agreement with the host state implements Union law and international-law requirements, subsequent detention, status, onward movement and access to remedies are in practice governed primarily by the agreement itself and the host state’s own legislation.

Improving the implementation of return decisions is a legitimate policy objective. However, current debates often focus on departures from EU territory rather than on achieving effective, sustainable and rights-respecting outcomes. Return hubs may help resolve particularly difficult cases and send a public message of enforcement. In addition, proponents of the concept hope that the prospect of transfer to a distant third state may encourage cooperation or voluntary return to the country of origin, as well as deterring prospective irregular migrants.

However, those assertions are not backed up by reliable data or clear precedent, while transfer to a third country may entail serious risks: prolonged and/or arbitrary detention, lack of access to lawyers and courts, refoulement, unsafe onward movement, or legal limbo in the host state. Return hub plans must therefore be closely scrutinised before implementation.

What return hubs are – and what they are not

Return hubs are the latest and most concrete expression of member states’ search for “innovative solutions” to shift elements of asylum and return management outside EU territory. Their appeal rests not only on the prospect of additional returns, but also on a signalling effect: reassurance for domestic publics and deterrence of prospective migrants. How realistic and valuable these effects are lies at the heart of the controversy.

Return hubs are intended for individuals who are already subject to an enforceable return decision. That sets them apart from inadmissibility procedures, including the safe-third-country concept, and offshore asylum processing. Under safe-third-country rules an asylum application may be rejected as inadmissible if the applicant is considered to have access to protection elsewhere, while offshore processing arrangements concern the location where initial asylum claims are assessed. Return hubs, by contrast, relate to the post-decision stage, when an individual has already been ordered to leave. The question is how and where the return decision is to be implemented.

In the EU context, return normally implies movement back to a place to which the person concerned is linked through nationality, residence or transit, or to a destination agreed with the individual. The logic of return hubs is different: transfer to an otherwise unrelated state, often in exchange for payments to the receiving state. Such transfers would generally be involuntary.

Three operational models are conceivable, each carrying distinct legal and political risks. First, a return hub may function as a temporary holding centre pending onward return to the country of origin. This relocates custody and case management while documentation and readmission are processed. As such, it merely changes the place where the problem is managed, rather than solving it.

Second, a return hub may become a longer-term destination if the host country offers secure and durable residence. This raises the question whether European states are effectively paying third countries to assume long-term or even permanent responsibility for people with whom they have no prior connection.

Third, a hub may be framed as a specific instrument for individuals who have been convicted of serious offences or are considered to pose security risks, and who cannot be returned directly. In this version, the hub is a specialised public security measure rather than a general response to low return rates. It would require strict criteria for inclusion, individual judicial review of detention or security grounds, and clear rules on sentence enforcement, costs and post-release status. Mere non-cooperation with immigration authorities should not qualify.

European precedents, but no template

No previous European arrangement with a third country fully corresponds to the operational models set out above. The initiatives often cited as precedents in the wider externalisation debate addressed different legal and operational problems. They do not provide a tested template for return hubs, but they illustrate the risks, costs and dependencies that can arise when elements of European asylum and migration policy are shifted beyond EU territory.

The UK-Rwanda scheme that London introduced in April 2022 aimed to outsource entire asylum procedures. The scheme was expensive and generated intense litigation before being politically abandoned; ultimately no one was forcibly transferred. UK government data put the combined cost of the Rwanda partnership and associated implementation of the Illegal Migration Act at £715 million. The UK-Rwanda example shows how offshore arrangements can create significant liabilities and sunk costs without ever becoming operational.

The 2023 Italy-Albania protocol is a bespoke bilateral arrangement under Italian jurisdiction that combines detention with offshore asylum processing. It was designed for accelerated asylum processing of a specific group of irregular migrants and subsequent direct return to their countries of origin. Legal challenges have so far prevented full implementation, and the facilities in Albania have been used only for a small number of cases. The agreement demonstrates that multi-purpose facilities for asylum and return can be established outside EU territory under a member state’s authority. But it does not show that such facilities produce faster, cheaper or more durable returns, nor that they can be easily replicated. Albania has underlined that it does not intend to extend the arrangement to other EU member states.

Finally, the 2016 EU-Turkey Statement has been central to the EU’s externalisation strategy over the past decade. Its main impact has been to incentivise Turkey financially to provide protection and basic services to Syrian refugees, while reinforcing its policing of its European borders. It has also been treated as a template for arrangements under which member states may declare certain asylum applications inadmissible. But specifically its return component remained limited in practice and has been suspended since 2020. The deal therefore underlines the difficulties involved in sending large numbers of returnees to a third country, even in a context of regional proximity, shared interests and substantial financial support.

The United States: a small, costly and selective precedent

Recent US practice is not a legal template for the EU, but does offer a useful empirical point of reference. Since January 2025, Washington has expanded third-country deportations, even as the legality of these transfers is being challenged in US courts. The comparison is relevant because conditions in the United States should make such transfers easier than in the EU: immigration enforcement and foreign policy are controlled by a single federal executive; US immigration law provides mechanisms for removal to third countries where return to the country of origin is not possible; and the government can combine transport and detention capacity with diplomatic, economic and security leverage. If remote third-country removals were readily scalable, these conditions should favour them. Their modest results therefore make the US experience instructive for the EU’s planned return hub arrangements.

While the Migration Policy Institute estimates that about 15,000 third-country removals took place in 2025, it is important to note that around 13,000 of those affected were sent to Mexico. Those transfers are more similar to cooperation with a neighbouring or transit state – as under the EU-Turkey Statement – than to a remote return hub. Excluding Mexico, there were roughly 2,000 transfers encompassing a heterogeneous and incompletely documented set of arrangements, including transfers to Panama, Costa Rica and Ghana. Full details are difficult to establish on account of transparency issues.

What is clear, however, is that the US has only a small group of arrangements that resemble the EU return hub concept, where distant states receive individuals with final orders of removal and then hold them, pursue their onward return or permit them to stay. A February 2026 report by Democratic minority staff of the US Senate Foreign Relations Committee found that five governments receiving direct payments had accepted about 300 transfers by January 2026. Around 250 of these occurred within the exceptional El Salvador operation, which was primarily incarceration-driven and was challenged over due process concerns. Other agreements limit the numbers involved and preserve broad discretion for the respective host state. Eswatini reportedly agreed to accept up to 160 deportees and had received 15 by November 2025; Rwanda agreed to consider up to 250 but initially admitted only a small number (seven as of January 2026).

Documented US cases raise question marks over efficiency and effectiveness. A Jamaican national transferred to Eswatini and a Mexican national transferred to South Sudan were both flown onward to their country of origin soon afterwards, at reported transport costs of approximately US$181,000 and US$91,000 respectively. In both cases, it was reported that the respective government had not been informed of the planned third-country repatriation of its citizen and had subsequently indicated that it had not refused to provide documentation. As such examples demonstrate, departure from the sending state is an inadequate measure of success. The relevant indicator is not departures, but the number of verified onward returns to countries of origin or lawful admissions to third countries that would not otherwise have occurred.

In addition, the US cases underline the risks that arise once an individual has been transferred into the custody of the receiving state. The key question is not only whether the transfer can be carried out, but whether detention conditions, access to remedies, protection against onward refoulement and prospects for release or onward return can be verified afterwards. Recent US arrangements appear to provide only weak monitoring and oversight mechanisms, which is especially problematic where receiving states – like Equatorial Guinea and El Salvador – have weak institutional transparency, entrenched corruption or documented human-rights concerns. The lesson for the EU is that careful partner selection and enforceable oversight are not secondary safeguards, but central conditions for lawful and sustainable third-country transfers.

Costs reinforce the same conclusion. Remote arrangements require diplomatic concessions, accommodation, detention, escorts, flights, monitoring and follow-up case management. The Senate minority report identified more than US$32 million in direct payments to five governments and at least US$7.2 million in flight costs; in some low-volume arrangements, expenditure exceeded US$1 million per person. Such expenditure may be politically defensible for a narrowly defined group of serious offenders or security threats. But the figures do not support the claim that remote third-country transfers can serve as a general response to low return rates. Claims about deterrence or improved compliance are also difficult to substantiate: third-country returns are embedded in a broader US enforcement agenda, including strengthened border controls, intensified internal enforcement and expanded detention, making it hard to attribute any wider behavioural effects to this instrument alone.

Hence, returns at scale still depend on the core return system – aimed at direct return to countries of origin – rather than remote third-country arrangements. The US case underscores that even where the political, institutional and material conditions for third-country removals are favourable, expanding such agreements beyond established legal safeguards risks violating national and international law. In the case of the EU, these legal constraints are likely to be even more significant, because member states operate under overlapping human rights obligations, including the EU Charter of Fundamental Rights and the European Convention on Human Rights.

From legal opening to political momentum

The European experience and the US precedents point in the same direction: remote third-country transfers can serve a political signalling function, but they remain costly, selective and dependent on fragile bargains. Much of the controversy over return hubs turns on how this trade-off is assessed. For proponents, visible enforcement can reassure domestic electorates, demonstrate state capacity and potentially deter some prospective migrants. Critics, by contrast, question whether such effects are realistic, legitimate or proportionate to the financial costs, diplomatic concessions, legal risks and possible distortion of the wider return system. These competing assessments of the costs and benefits help explain why the mixed record of third-country transfers has not weakened political momentum behind return hubs in Europe. Now that the new Return Regulation provides the legal opening, an increasing number of Member States are seeking to translate the concept into practice.

Austria’s May 2026 mobility agreement with Uzbekistan illustrates the emerging search for partners. It provides for Uzbekistan to serve as a transit route for removals of third-country nationals, in particular Afghans. Although this agreement does not officially establish a return hub, Uzbekistan has reportedly been discussed as a potential host state, alongside Rwanda, Armenia and Mauritania. Persistent uncertainty over likely partner countries contrasts with growing political momentum within the EU. In recent months, a core group of member states – Austria, Denmark, Germany, Greece and the Netherlands – has been pushing for pilot return hubs by the end of 2026. Other EU member states have also expressed their support, calling for funding from the EU budget and the involvement of international organisations. France and Spain have rejected the concept, though elections in 2027 may alter their positions. After the Ceuta crisis, several European leaders and the EPP leadership used the incident to renew calls for third-country return hubs, even though the incident constituted primarily a border-management and immediate readmission challenge rather than a return-hub scenario. At the time of writing, Rwanda has reportedly entered more formal negotiations with the countries belonging to the core group of EU member states, but concrete agreements are yet to emerge.

Even if this momentum leads to the establishment of a pilot scheme, this would not change the basic scale problem. Any return hub operationalised by a European government or minilateral coalition would have to be understood as a residual instrument. Member states issue several hundred thousand return decisions each year, while the US experience suggests that a single hub would probably handle only a few hundred cases a year. It therefore cannot be expected to meaningfully increase the EU’s overall return rate.

Key risks associated with future return hubs

A first cross-cutting risk is diminished scrutiny after transfer. In ordinary return procedures, key legal risks are assessed before removal, including non-refoulement, access to remedies and protection against arbitrary detention or inhuman treatment. In a return hub arrangement, by contrast, some of the most serious risks may arise only after the person has left EU territory: detention conditions, access to legal representation and remedies, onward transfer, or refoulement. Because removal is legally complete upon arrival, political and administrative attention may shift away from the person concerned precisely when safeguards become harder to verify.

Another risk is weak additionality. A hub adds value only if it produces lawful and durable outcomes for people whose return could not be achieved through existing channels. It may also have indirect value if a credible prospect of transfer encourages direct return, but this effect would need to be demonstrated, not assumed. If the country of origin is willing to document and readmit the person, third-country transfer merely adds cost and complexity, as the US experience suggests. If onward return remains impossible, the hub becomes less a temporary return instrument than a form of externally financed long-term admission or containment. Yet prospective host states are least likely to accept those whose return is hardest to resolve, including people whose identity cannot be reliably established.

A third risk is diversion. Once a facility exists, administrators may see incentives to populate it. Fixed costs, negotiated capacity and political sponsorship could encourage transfers to return hubs even in cases where direct return to country of origin might have been achieved through documentation, consular engagement, assisted voluntary return or reintegration support.

A fourth risk is policy entrapment. Return hub agreements require diplomatic concessions, infrastructure, funding, security arrangements and political capital. Once these costs have been incurred, poor results may lead not to closure, but to attempts to rescue the project through higher payments, weaker safeguards or diplomatic or political concessions. The EU’s own experience demonstrates the vulnerability that arises when operational control is delegated. Turkey’s 2020 border opening illustrates how migration pressure can become a bargaining chip. Similarly, recent US experience shows how a third-country removal agreement can be leveraged by partner countries: after accepting US deportees, South Sudan reportedly requested sanctions relief, visa concessions and US support for the prosecution of an opposition leader.

A fifth risk lies in a potential inversion of priorities. The core return system depends on determination of nationality, documentation, consular cooperation, direct return, readmission diplomacy, case management, voluntary return support and reintegration. These instruments possess less political visibility than a facility abroad. If return hubs divert attention and resources away from the core return system, they may end up weakening the system they are supposed to strengthen. Reintegration is especially vulnerable because its effects are difficult to measure and attribute. Yet this should not be mistaken for limited relevance. Reintegration support cannot by itself prevent future movement, but it can strengthen stability and social cohesion in receiving communities as well as the willingness of countries of origin to cooperate on readmission.

Conditions for a limited pilot

Because pilots may differ by region and model, and may be negotiated bilaterally, common minimum standards are essential. The new Return Regulation requires an agreement or arrangement with the host state, but not a legally binding treaty. Participating member states should go beyond this minimum and commit to binding conditions on function, target group, legal responsibility, monitoring, evaluation and financing.

Transferring state to remain responsible until sustainable outcome

Any agreement should make the transferring state legally responsible until verified return to the country of origin or lawful admission elsewhere. This responsibility must apply to each person transferred, not only to the facility as such. Agreements should guarantee access to courts, lawyers, consular authorities, independent monitors and relevant international organisations, and include a funded obligation to return the person to the EU if detention becomes unlawful, conditions fall below agreed standards, onward return to the country of origin remains impossible beyond a defined period, the host state ceases cooperation or the agreement is terminated.

Define the function and target group narrowly

Any agreement should specify from the outset which of the three operational models identified above it is intended to implement: a hub for temporary stays pending onward return, a longer-term destination offering lawful and durable admission, or a specific instrument aimed at a public security cohort. The first two models imply different responsibilities for the transferring state and the host country. The agreement should also define the target group and exclude use as a general overflow mechanism for individuals that cannot be removed from border procedures within twelve weeks. For the third model, the threshold should be based on convictions or reviewable security evidence.

Choose partners by safeguards, not availability

A pilot should proceed only with a partner country that can credibly guarantee lawful and rights-respecting transfers: legal status, conditions of stay, custody rules, independent monitoring, access to remedies, safeguards against refoulement, consequences of breach and a defined endpoint for unresolved cases. This will narrow the partner pool. States with stronger administrative and judicial systems may lack incentives to assume responsibility for third-country nationals with whom they have no prior connection. EU accession candidates, for instance, are likely to prioritise faster accession over serving as external buffer states for irregular migration. More willing partners may demand substantial concessions or offer weaker safeguards. This trade-off, or even hard limit, applies equally to pilot projects.

Require an additionality test for every transfer

Each transfer should record why direct return is currently unavailable, why assisted voluntary return has not resolved the case and how the hub is expected to improve the prospect of a sustainable return. This prevents straightforward cases from being diverted to populate a facility or produce transfer figures. The assessment should be auditable and should apply pre-transfer, and not only during post-transfer evaluation. Any pilot should have hard limits on capacity, target groups, budget and duration. Renewal or expansion should require independent evaluation and a new political decision rather than following automatically from the initial arrangement or occurring by default. A pilot should not be financed at the expense of assisted voluntary return, reintegration support or longer-term cooperation with countries of origin.

Evaluate outcomes, not departures

Reporting should distinguish each stage and outcome: transfer to the hub, onward return, lawful admission, continued detention, release, absconding, further transfer or readmission to the EU. The benchmark should not be the number of people removed from EU territory, but whether a return hub produces lawful, rights-respecting and sustainable outcomes that could not have been achieved more reliably and humanely through direct return, assisted voluntary return, origin-country cooperation, transit arrangements or reintegration support. The overall financial and administrative costs should be calculated per durable resolution and compared with a similar cohort under existing return procedures. Governments should also make publicly available the personnel, funding and diplomatic concessions devoted to the hub alongside what is spent on documentation, readmission cooperation, assisted voluntary return and transit-country arrangements.

Protect the core return system, including reintegration

The resources devoted to a pilot return hub should be evaluated alongside investments in readmission cooperation with countries of origin, consular documentation, assisted voluntary return, and reintegration. Reintegration support could be embedded more systematically in local public services, community-based support and protection structures, rather than treated as a short-term individual grant attached to departure.

Return hubs may have a limited role for a small subset of people whose return cannot otherwise be carried out. They should not become the principal symbol of a return policy whose performance will continue to depend on cooperation with countries of origin, assisted voluntary return, documentation, readmission and arrangements with neighbouring and transit states. If a pilot cannot meet the tests of additionality, durability and non-distortion, it cannot resolve the EU’s return problem. It would create an expensive mechanism for relocating unresolved cases at the price of making the wider system harder, not easier, to fix.

Dr Raphael Bossong is Deputy Head of the EU/Europe Research Division and Dr Anne Koch is a researcher in the Global Issues Research Division at SWP. Zefitret Abera Molla is a doctoral researcher at Freie Universität Berlin. This SWP Comment was written as part of the project “Migration and Displacement in a Shifting Global Order”, funded by the German Federal Ministry for Economic Cooperation and Development.