EU Return Hubs 2026: why the German-Dutch model needs an integration contract

In recent months, a clear political direction has emerged within the European Union: externalizing migration control through the creation of return hubs in third countries. A coalition led by Germany and the Netherlands, alongside Austria, Denmark, and Greece, is actively exploring agreements with countries such as Rwanda, Uganda, and Tunisia. Italy’s arrangement with Albania has already demonstrated that what once seemed politically unfeasible is now becoming operational reality.

For a U.S. audience, this debate may sound familiar. It echoes long-standing discussions about offshore processing, third-country agreements, and the tension between border enforcement and due process. But the European case presents a distinct legal and structural problem: the system is being built without a coherent internal mechanism to evaluate integration over time.

That is the core issue.

Return hubs are, by design, reactive tools. They intervene at the final stage of the migration cycle—when an individual has already lost legal status or is deemed removable. In other words, they manage failure. What they do not address is how to prevent that failure in the first place.

This creates three major weaknesses.

First, a structural inefficiency. If the only mechanism available is removal after the fact, the system will inevitably be overwhelmed. Without a prior filter, every case—integrated or not—risks ending up in the same enforcement pipeline.

Second, high financial and political costs. Offshore centers require complex bilateral agreements, sustained funding, and diplomatic trade-offs. As seen in comparable discussions in the United States, these arrangements are not only expensive but also politically fragile.

Third—and most importantly—a legal risk. Human rights organizations have already warned that such hubs may become “legal black holes,” where access to legal remedies is limited and procedural guarantees are weakened. For European systems bound by the European Convention on Human Rights, this is not a marginal concern—it is a structural vulnerability.

The problem, therefore, is not the existence of return hubs per se. The problem is that they are being developed in isolation, without a preventive legal framework capable of distinguishing, in a transparent and objective way, who should remain and who should not.

This is where the Italian model offers an overlooked solution.

Italy already has a legal instrument that introduces a fundamentally different logic: the integration contract, established by Presidential Decree No. 179 of 2011. Unlike static immigration systems that grant or deny status at a single point in time, this mechanism creates a dynamic, ongoing evaluation of integration.

It is based on measurable criteria: employment, language proficiency, and respect for the law. These are not ideological benchmarks but concrete indicators that can be verified over time. The right to remain is therefore not automatic or permanent—it is conditioned on a continuous process of integration.

From a U.S. perspective, this resembles a hybrid between a points-based system and conditional residency, but with a stronger emphasis on ongoing compliance rather than initial selection.

If integrated into the broader European framework, such a mechanism would fundamentally change the role of return hubs. Instead of being emergency tools used after systemic failure, they would become the final step in a structured process—applied only after a clear, documented, and periodically verified lack of integration.

This would also address one of the main criticisms raised by NGOs: the absence of transparent criteria. A system based on periodic verification reduces arbitrariness, strengthens legal certainty, and ensures that decisions are grounded in objective factors rather than discretionary assessments.

The key point is simple, but often overlooked.

Migration policy cannot rely solely on border control and removal mechanisms. It must also define, in legal terms, what it means to integrate—and it must verify that integration over time.

Without this, return hubs risk becoming expensive, legally contested, and ultimately ineffective instruments.

With it, they can be part of a coherent system.

The European debate is now entering a decisive phase. The question is not whether return hubs will be implemented—they already are. The real question is whether Europe will equip itself with the legal tools necessary to make them sustainable.

In this context, the Italian integration contract is not just a national instrument. It is a model that deserves serious consideration at the transatlantic level.

Avv. Fabio Loscerbo
Lobbyist – EU Transparency Register No. 280782895721-36
ORCID: https://orcid.org/0009-0004-7030-0428

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