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 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.
About the author
Dr Raphael Bossong is Deputy Head of the EU/Europe Research Division at SWP.
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.