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

In recent months, a clear policy direction has taken shape across parts of Europe: the externalisation of migration management through the creation of return hubs in third countries. A coalition including Germany, the Netherlands, Austria, Denmark and Greece is actively pursuing this strategy, exploring agreements with countries such as Rwanda, Uganda and Tunisia. Italy’s arrangement with Albania has already shown that what was once politically controversial is now becoming operational.

For a UK audience, this debate resonates immediately. It sits alongside ongoing discussions about offshore processing, third-country arrangements and the balance between migration control and legal accountability. The UK’s own experience—particularly with proposals involving Rwanda—has highlighted how difficult it is to reconcile enforcement with the rule of law.

The European approach risks falling into the same structural trap.

Return hubs are inherently reactive. They intervene only at the final stage, when an individual has already fallen into irregular status or is subject to removal. In effect, they manage the outcome of a system that has already failed. What they do not provide is a mechanism to prevent that failure.

This exposes three fundamental weaknesses.

First, a systemic inefficiency. Without a prior framework to assess integration, the system lacks any meaningful differentiation. Individuals with very different trajectories—those who are integrated and those who are not—are treated within the same enforcement logic.

Second, high political and financial costs. Offshore arrangements require complex bilateral agreements, ongoing funding and a degree of geopolitical stability that cannot be taken for granted. As the UK experience has shown, such models are both expensive and politically contentious.

Third, and most critically, a legal vulnerability. Concerns have already been raised about the risk of creating “legal black holes”—spaces where access to justice is limited and procedural safeguards are weakened. In a European context bound by the European Convention on Human Rights, this is not a marginal issue but a central one.

The core problem is therefore not the existence of return hubs as such, but the absence of a coherent legal framework in which they operate.

They answer the question of how to remove, but not how to govern presence.

This is where the Italian model offers a different perspective.

Italy already has a legal instrument that introduces a preventive logic: the integration contract, established by Presidential Decree No. 179 of 2011. This mechanism shifts the focus from a one-off decision on residence to an ongoing evaluation of integration.

It is based on clear, verifiable criteria: employment, language proficiency and compliance with the law. These are objective indicators that can be assessed over time, allowing the right to remain to be linked to a continuous and demonstrable integration pathway.

For a UK audience, this may be understood as a form of conditional residence grounded not only in entry criteria, but in sustained compliance over time.

If applied at a European level, such a mechanism would fundamentally reshape the role of return hubs. They would no longer function as emergency tools deployed after systemic breakdown, but as the final step in a structured and transparent process.

This would also address a key criticism: the lack of clear standards. A system based on periodic verification reduces arbitrariness and strengthens legal certainty, ensuring that decisions are grounded in measurable factors.

The UK debate has long been framed around control versus compassion. What is often missing is a third dimension: verification.

Without a mechanism to assess integration over time, enforcement tools alone cannot produce a stable system.

With it, they can.

The real issue is not where individuals should be relocated outside Europe.

The real issue is how the right to remain is defined, measured and maintained within it.

In this context, the Italian integration contract is not simply a national tool. It represents a model that could inform a more coherent and legally sustainable migration policy—both in Europe and beyond.

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

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