Designating ‘safe’ countries may appear to offer a practical solution to Europe’s migration challenges, but it raises profound legal and ethical concerns. The legality of safe country lists, particularly in the context of the European Union’s (EU) migration and asylum policies, has been highly contested^[1]. EU law utilises the ‘Safe Third Country’^[2] (STC)^[3] concept to allow asylum applications to be declared inadmissible if an applicant could find effective protection in a third non-EU country. Revised in the Pact on Migration and Asylum and its implementing Asylum Procedures Regulation (APR), the STC concept aims to expedite processing, reduce pressure on national asylum systems, and increase returns. Promoted as tools to streamline and expedite asylum procedures, these lists nevertheless risk breaching international and EU law, particularly the non-refoulement principle and the right to individualised assessments of asylum claims. Reckoning with unprecedented numbers of migration flows, the EU has increasingly invested in migration partnerships with ostensibly ‘reliable’ partners, aiming to develop so-called ‘proactive containment’^[4] strategies. Yet, these EU-tailored partnerships with third countries deemed ‘safe’ remain deeply problematic, especially when the protection standards of the designated ‘safe’ countries are questionable.

The EU’s 2024 agreement with Lebanon, which includes financial aid to bolster Lebanon’s capacity to intercept migrant boats and manage migration, exemplifies the operationalisation of safe country lists for the purpose of border externalisation. Cyprus’s announcement on April 13, 2024, to suspend the processing of asylum applications^[5] for Syrian nationals, coupled with its lobbying^[6] in Brussels to consider declaring parts of Syria as safe for repatriation,^[7] illustrates the political motivations that often underpin such designations. Hence, these strategies, although formally framed as enhancing regional migration management, nonetheless risk shifting the EU’s responsibilities onto third countries with dubious human rights records, raising doubts about their legality under international and European law.

Notwithstanding, recent legal developments have further complicated the landscape of safe country designations. This blog examines the EU’s growing reliance on safe country lists, focusing on the legal implications of designating third countries as ‘safe’ and the consequent impact of these designations on the right to individualised asylum procedures. It explores the evolving legal framework surrounding Safe Third Country (STC) designations, drawing on key jurisprudence, including the European Court of Human Rights (ECtHR) 2025 judgment in M.A and Z.R. v. Cyprus ^[8] where the Court’s ruling underscored the dangers associated with blanket assumptions of safety without individual assessments, as well as the role of the Court of Justice of the European Union (CJEU)^[9] in shaping legal standards for such designations. In addition, the blog engages with recent legal proceedings such as Ireland’s High Court,^[10] which has emerged as an important forum for contesting the legality of safe country designations within national asylum procedures.

Rather than offering a merely doctrinal analysis, the paper situates safe country designations within the EU’s broader externalisation agenda. It therefore critically examines how legal frameworks have been increasingly instrumentalised to displace accountability for ensuring the protection of asylum seekers onto third (partner) countries, arguing that the growing entanglement of safe country policies and externalisation strategies risks eroding fundamental asylum guarantees enshrined under EU and international refugee law.

Part I- Redefining Safety: Legal Foundations of Safe Country Lists in EU Migration Law

The concept of STC designations is deeply embedded in the legal architecture of the EU’s asylum system, which aims to balance^[11] the protection of asylum seekers with effective management of migration flows. Within the Common European Asylum System (CEAS), the Asylum Procedures Directive and the Qualification Directive play a central role. These instruments outline both procedural and substantive rights of asylum seekers, including the requirement that asylum claims be assessed on an individual basis, rather than on generalised assumptions about a claimant’s country of origin or transit. (Directive 2011/95/EU, Art. 4)^[12].

STC provisions, codified under Article 38 of the Asylum Procedures Directive (2013/32/EU),^[13] aim to expedite asylum processes by presuming that certain third countries can provide effective protection, allowing applicants to be transferred there to request asylum. Nevertheless, this approach has drawn growing criticism for its potential conflict with the right to an individualised asylum assessment required by Article 4 of the Qualification Directive. Such individualised assessments are a conditio sine qua non for determining whether an applicant may face risks such as torture or inhuman treatment upon return. Blanket applications^[14] of STC designations not only undermine the ad hoc principle but also raise serious concerns about violations of the non-refoulement principle,^[15] which prohibits sending individuals to a country where they face a real risk of persecution, torture, or inhuman or degrading treatment–a cornerstone of both international refugee law (1951 Refugee Convention, Art. 33) and European human rights law (ECHR, Art. 3).

Relying on the presumption that a country is ‘safe’ because of its inclusion on a designated list of STC caries significant risks, as exemplified in the M.A. and Others v. Cyprus^[16]. In this case, the applicant, a Syrian national of Kurdish origin, was considered by the Cypriot authorities to be unlawfully staying in the Republic, and thus deportation and detention orders were issued against him despite the pending asylum proceedings. He was summarily expelled to Lebanon, which Cyprus treated as effectively ‘safe’ for the purposes of its readmission and border policies, without any examination of his individual protection needs. The ECtHR found a violation of Article 13 in conjunction with Articles 2 and 3 of the ECHR, as the applicant had no effective remedy to challenge these orders (§119). The case illustrates how reliance on STC designations, in the absence of robust safeguards, can facilitate wrongful deportations and undermine the individualised assessments that lie at the heart of refugee protection.

These legal concerns have become more pressing in light of the EU’s evolving externalisation agenda. The 2020 New Pact on Migration and Asylum, and its 2024 update, marked a shift towards greater reliance on tailored partnerships with third countries, including Lebanon,^[17] Egypt,^[18] Tunisia,^[19] Libya,^[20] and Mauritania,^[21] to manage migration outside the EU borders. These partnerships, often described as ‘cash-for-migration-control’^[22] deals, involve financial assistance, capacity-building, and readmission agreements that enable the expediting of returns of asylum seekers. While presented as cooperative frameworks, such deals often fail to provide rigorous individualised assessments, thereby effectively operationalising Safe Third Country logic on extraterritorial grounds.

The 2024 Asylum Procedures Regulation (ARR)^[23], part of the broader EU Pact on Migration and Asylum, seeking to reform the Common European Asylum System (CEAS), reinforces Safe Third Country logic–that is, the presumption that certain third countries can provide effective protection, allowing Member States to reject an asylum claim as inadmissible, based on a loosely defined ‘connection’ between the applicant and the country. Importantly, there is no requirement for prior individualised assurance that the third country will actually offer any effective protection. This facilitates a de facto presumption of safety, reduces legal scrutiny, and contributes to an expanding and politically driven list of ‘safe’ partners. Such lists are politically driven because designations are often shaped by diplomatic, economic, and strategic considerations–such as securing cooperation on border management, readmission arrangements, or development aid–rather than solely by objective assessments of refugee protection. In practice, this allows the EU to externalise asylum responsibility and manage migration flows according to broader political goals,^[24] rather than purely on protection standards.

A blatant example of this is the EU’s partnership with Tunisia, formalised in 2023 under the ‘Team Europe’^[25] framework, which included the EU, Italy, and the Netherlands. The agreement provided 150 million euros in migration-related funding–including border management and combating irregular migration– and 105 million euros in budgetary support for the Tunisian government. Despite Tunisia’s well-documented record^[26] of arbitrary detention, racialised violence, and lack of a functioning asylum system, the deal proceeded without robust human rights safeguards. A minimal assessment of the political risks to asylum seekers and migrants highlights how strategic and political considerations often outweigh protection standards in shaping such agreements. Following the agreement, reports proliferated of mass expulsions of sub-Saharan Africans to desert areas near the Libyan and Algerian borders. According to 2025 reports,^[27] expulsions marked by street arrests, interceptions at sea, and forced removals by bus under cover of night have become systematic and large-scale, with migrants reportedly being abandoned in remote desert zones. Such treatment heavily contradicts basic protection standards and underscores the dangers of prioritising political diplomacy over legal safeguards in STC determinations.

Similarly, the EU’s 2024 partnership with Lebanon,^[28] framed around financial support for maritime interceptions and returns, raises significant legal and ethical concerns. Despite hosting the highest number of refugees per capita, Lebanon is not a signatory to the 1951 Refugee Convention, has limited asylum infrastructure, and has documented instances of refoulement. Lebanon does not recognise Syrians as refugees, instead designating them as ‘displaced’, and has adopted coercive measures^[29] including summary deportations without individual assessments, arbitrary arrests, and discriminatory mobility restrictions, all of which have been criticised by domestic groups as unconstitutional^[30] and in breach of the non-refoulement principle. Against this backdrop, the EU’s treatment of Lebanon as a de facto STC under the 2024 partnership reflects a politically driven presumption of safety, untethered from verifiable legal protections or access to effective asylum procedures.

These examples demonstrate how EU externalisation strategies operationalise presumptions of safety beyond the formal legal STC framework. While legal STCs allow Member States to declare an asylum application inadmissible with legal safeguards and procedural review, political or de facto designations–applied in the EU’s partnerships with Tunisia, Lebanon, and Libya–treat countries as ‘safe’ for the purposes of border management and migration control, without guaranteeing access to proper asylum procedures. By extending the logic of presumed safety in this way, the EU shifts legal responsibility onto third countries where human rights protections are inadequate, often guided by strategic, diplomatic, or economic considerations rather than objective refugee protection criteria. In doing so, externalisation strategies risk undermining the individualised assessments and core guarantees of asylum protection enshrined in EU and international law.

Part II – Challenging Presumed Safety: Jurisprudence and Legal Accountability in Safe Third Country Designations

The principle underpinning STC designations rests on the presumption that certain states offer effective protection to asylum seekers, thereby allowing EU Member States to shift responsibility for asylum processing to these designated countries. The 2024 Asylum Procedures Regulation broadens this concept: a country no longer needs to grant refugee status to be considered safe; it suffices that the applicant can enjoy some form of protection. This represents a significant departure from prior criteria but raises new concerns, as the receiving state may lack full procedural guarantees and rights under EU and international law. Crucially, a STC designation means the third country–not the EU Member State where the application was initially filed–will be expected to examine the asylum claim. When applied without robust safeguards and individualised assessments, such designations risk undermining the right to asylum and the non-refoulement principle, a risk increasingly highlighted by judicial scrutiny of blanket STC applications.

A pivotal development in this context is the 2025 judgment of the ECtHR in M.A and Z.R v. Cyprus,^[31] where the Court examined whether Cyprus’ reliance on an STC designation–in this case, Lebanon–without affording the applicants an opportunity to rebut the presumption of safety, violated Articles 3 (protections against inhuman or degrading treatment) and 13 (the right to an effective remedy) of the ECHR. The Court stressed that any return decision must be grounded on an individualised, case-by-case assessment of the risk the applicants might face upon return. In this regard, it found that Cyprus had failed to conduct such an assessment, instead relying on a generalised presumption of safety stemming from its bilateral agreements^[32] with Lebanon, including a 2020 agreement under which Cyprus could return migrants intercepted en route from Lebanon. The ECtHR concluded that this constituted a breach of the applicants’ rights, reaffirming that the non-refoulement principle cannot be circumvented through political arrangements or formalised country listings. The Court’s ruling was significant in reiterating that applicants must not be subjected to collective expulsions or denied access to meaningful asylum procedures on the basis of generalised or politically expedient^[33] designations of safety.

In a similar vein, the CJEU has significantly shaped the jurisprudence surrounding the ‘safe country’ concept in asylum law. In the landmark joined cases of N.S. v. United Kingdom and M.E. v. Ireland (C-411/10 and C-493/10),^[34] the Court examined the operation of the Dublin II Regulation^[35], which governs which EU Member State is responsible for examining an asylum application, in light of the Charter of Fundamental Rights of the EU. Although these cases dealt with intra-EU transfers rather than Safe Third Countries, the reasoning nevertheless has wider relevance, underscoring the need for individualised assessments even when there is a strong presumption of safety. The CJEU held that EU law precludes the use of a conclusive presumption that all Member States comply with fundamental rights obligations. Specifically, Article 4 of the Charter must be interpreted to mean that Member States may not transfer an asylum seeker to another State, even an EU Member State, if they know, or ought to reasonably know, that there are systemic deficiencies in the receiving state’s asylum procedures and reception conditions that create substantial grounds for believing that the individual would face a real risk of inhuman or degrading treatment. Where such risks exist, and transfer is thus precluded, the Member State must examine whether another State is responsible under the Regulation’s criteria, and, failing that, proceed to examine the asylum application itself. This judgment is significant in that it undermines blind reliance on presumed safety, whether within or beyond the EU, where fundamental rights are at stake.

Reinforcing this jurisprudence, the CJEU in the Case C-564/18 ((LH v Bevándorlási és Menekültügyi Hivatal)^[36] of 19 March 2020 provided further clarification on the application of the STC concept. Interpreting Article 38(2) of the Recast Asylum Procedures Directive 2013/32/EU,^[37] the Court held that a concrete, individualised assessment is required to determine whether the third country genuinely offers effective protection to the applicant. As per the Court, transit alone does not constitute a sufficient connection^[38] to render return to that country reasonable, nor does it justify bypassing the asylum procedure in the Member State where the application was lodged. This ruling significantly limits the Member States’ ability to apply STC designations in a mechanical or automatic manner, particularly in the absence of a transparent, case-specific methodology for assessing safety in light of the applicant’s personal circumstances.

However, despite this clear jurisprudence, the application of the aforementioned rulings has been complicated by ongoing tensions between EU legal standards and national administrative practices. A key example is the compatibility of Article 91(1)(f) of the Greek Asylum Code (Law 4939/2022) with the EU acquis,^[39] particularly as interpreted by the CJEU in its case law on the STC concept. This provision allows for the consideration of transit through a third country as a relevant connection that may justify the application of the STC concept. Yet, consistent with the CJEU’s interpretation of Article 38(2) in C-564/18 case, transit alone cannot be treated as a sufficient or automatic ground for deeming a country safe.^[40] In practice, however, this principle has been inconsistently applied. Internal guidelines, for instance, issued by the Greek Asylum Service in 2021,^[41] though not publicly available, reportedly provide that applications by nationals of Syria, Afghanistan, Pakistan, Bangladesh, and Somalia may be considered admissible if more than one year has elapsed since transit through the third country and no substantial ties have been maintained during that period. While this may reflect an attempt to introduce temporal and relational criteria, the opacity of such guidelines raises concerns about legal certainty, accountability, and consistency in decision-making. Moreover, the continued reliance on politically driven national guidelines, despite binding CJEU jurisprudence, suggests a disconnection between formal legal obligations and operational practice. These practices risk undermining the procedural rights guaranteed under Article 46 of Directive 2013/32/EU^[42] and the absolute nature of the non-refoulement obligation enshrined in Article 33 of the 1951 Refugee Convention and Article 3 ECHR. Without transparent, individualised assessments grounded in verifiable protection conditions, STC designations risk remaining legally contestable and ethically fragile.

Part III – Judicial Resistance and Legal Recalibration: Reining in the Expansion of Safe Country Designations?

While the EU’s political turn toward externalisation has driven the widespread use of STC mechanisms, recent judicial developments across Member States signal a growing resistance to the unchecked expansion of such designations. Courts in Ireland^[43] and Greece,^[44] in tandem with the CJEU in Grand Chamber formation,^[45] have begun to push back against the erosion of procedural guarantees and legal accountability that such practices often entail.

In a landmark 2024 decision, the Irish High Court^[46] held that the designation of the UK as a ‘safe third country’ under the International Protection Act 2015 was unlawful. The judgment centred on the Act’s failure to require the Minister for Justice to assess whether a transferee would face a risk of ‘serious harm’,^[47] a gap that breached Article 3(3) of the Dublin III Regulation. Notably, the Court held this provision continues to impose binding minimum standards on Member States when transferring asylum seekers, despite the UK’s departure from the EU. The Court also stressed that while Ireland did not adopt the Recast Procedures Directive or the Qualification Directive, the safeguards contained therein remain relevant for ensuring compliance with EU law. The ruling identified a significant gap between the procedural safeguards prescribed by EU law and those embedded in the 2015 Act,^[48] including the absence of a sufficiently robust methodology to prevent unlawful transfers. Although the Court did not rule directly on the impact of the UK-Rwanda policy, it acknowledged that the Minister had considered the UK-Rwanda Memorandum of Understanding and that concerns over onward refoulement contributed to the broader legal uncertainty surrounding the designation.

In February 2025, the Irish Court of Appeal^[49] upheld the High Court’s decision, ruling the state’s appeal to be moot in light of the repeal of the UK’s STC designation through the Civil Law, Criminal Law and Superannuation (Miscellaneous Provisions) Act 2024. This new legislation introduced additional safeguards to ensure compliance with EU law in international protection proceedings. The Court confirmed that the legislative reforms addressed the procedural deficiencies identified by the High Court–concerns that had rendered the prior STC designation problematic–thereby making the appeal effectively irrelevant.^[50] These rulings represent a broader judicial pushback against blanket STC designations that fail to meet EU law’s stringent protection standards. By reaffirming the necessity of individualised assessments and reliance on current and reliable country information, the Irish courts have contributed to a growing EU-wide trend toward reinforcing legal safeguards against the risks posed by externalisation strategies.

This judicial stance is echoed beyond Ireland. In April 2025, the Greek Council of State^[51] annulled a Joint Ministerial Decision designating Türkiye as a safe third country^[52] for asylum seekers from Syria, Afghanistan, Somalia, Pakistan, and Bangladesh. The Court found that the designation lacked a proper assessment of Türkiye’s human rights record and failed to meet the legal criteria required under national and EU law. Notably, the judgment cited CJEU Case C-134/23,^[53] which reaffirmed that, given the suspension of readmissions to Türkiye since March 2020, asylum applications cannot be rejected as inadmissible under the STC concept. Nevertheless, in defiance of this ruling, and even before its official publication, the Greek government reissued a substantively identical Joint Ministerial Decision. Undoubtedly, this raises serious concerns about executive disregard for judicial authority and constitutional principles, such as legality and legal certainty. Taken together, these developments expose the fragility of expansive STC practices under judicial scrutiny and underscore a growing disjunction between executive-led externalisation strategies and the legal constraints consistently reaffirmed by national and EU courts.

Conclusion

As the EU deepens its reliance on safe country lists and externalised migration control, the line between procedural efficiency and legal accountability grows increasingly blurred. This blog has shown that STC designations are used, first in conjunction with externalisation strategies to shift responsibility for refugees onto third countries with questionable human rights protections, bypassing individualised assessments and undermining the procedural safeguards enshrined in EU and international law. Second, these practices carry political and strategic dimensions, allowing the EU to leverage financial and diplomatic incentives to secure third country cooperation, effectively turning migration management into a bargaining chip.

Finally, jurisprudence from the ECtHR, CJEU,^[54] and national courts has pushed back against these trends, insisting on robust safeguards and case-by-case assessments even when presumptions of safety exist. Importantly, the CJEU is now set to rule in Case C-718/24,^[55] referred by the Administrative Court of Sofia City (Bulgaria), on whether the STC concept can be applied in the absence of a legislative basis and without a meaningful connection between the applicant and the third country. This case could prove pivotal in clarifying the outer limits of lawful application under EU asylum law. If left unchecked, the expansive use of STC practices risks entrenching a transactional logic that not only undermines procedural safeguards but also erodes the EU’s credibility as a values-based global actor. Recent political agreements in December 2025 establishing the first EU-wide list of Safe Countries of Origin and revising return procedures suggest this trajectory is accelerating rather than being curbed by judicial oversight.^[56]

Footnotes

1. Baya Amouri, “Rethinking the ‘Safe Third Country’ Concept: Insights From the Court of Rome’s Ruling on Italy’s Transfer of Asylum Seekers to Albania,” Refugee Law Initiative Blog, February 6, 2025, https://rli.blogs.sas.ac.uk/2025/02/06/rethinking-the-safe-third-country-concept-insights-from-the-court-of-romes-ruling-on-italys-transfer-of-asylum-seekers-to-albania/ (accessed May 5, 2025). ↑
2. European Parliamentary Research Service, Safe third country concept in EU asylum law, EPRS briefing, December 2024, https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2024)767148 (accessed May 5, 2025). ↑
3. Mariana Gkliati, “The New Frontier of Externalisation: Safe Third Countries and Return Hubs – Key Changes and Implications” Externalizing Asylum, 15 April. https://externalizingasylum.info/the-new-frontier-of-externalisation-safe-third-countries-and-return-hubs-key-changes-and-implications/  ↑
4. Mariana Gkliati, “Why Externalisation Policies Fail: A Critical Analysis” Externalizing Asylum, July 3, 2024, https://externalizingasylum.info/why-externalisation-policies-fail/ (accessed May 5, 2025). ↑
5. Al Jazeera, “Cyprus suspends asylum applications for Syrians as arrivals rise,” April 14, 2024, https://www.aljazeera.com/news/2024/4/14/cyprus-suspends-asylum-applications-for-syrians-as-arrivals-rise (accessed May 6, 2025). ↑
6. Al Jazeera, “Cyprus suspends asylum applications for Syrians as arrivals rise,” April 14, 2024, https://www.aljazeera.com/news/2024/4/14/cyprus-suspends-asylum-applications-for-syrians-as-arrivals-rise (accessed May 6, 2025). ↑
7. Menelaos Hadjicostis, “Cyprus calls on the EU to rethink Syrian safe zones for eventually repatriating Syrian migrants,” The Independent, 22 September 2023, https://www.independent.co.uk/news/nicosia-ap-interior-ministry-syrians-spain-b2416730.html (accessed May 6, 2025). ↑
8. European Court of Human Rights, M.A. and Z.R. v. Cyprus, App. No. 39090/20, judgment of October 8, 2024, HUDOC, https://hudoc.echr.coe.int/eng?i=001-236141 (accessed May 6, 2025). ↑
9. Refugee Support Aegean and Greek Council for Refugees, “CJEU ruling on the concept of ‘safe third country’” (press release), October 2024, https://rsaegean.org/en/cjeu-ruling-on-the-concept-of-safe-third-country/ (accessed May 7, 2025). ↑
10. Ellen O’Riordan, “Ireland’s declaration of UK as ‘safe third country’ is unlawful, High Court rules,” The Irish Times, March 22, 2024, https://www.irishtimes.com/crime-law/courts/2024/03/22/irelands-declaration-of-uk-as-safe-third-country-unlawful-rules-high-court/ (accessed May 7, 2025). ↑
11. Steve Peers, “The New EU Asylum Laws: Taking Rights Half-Seriously,” Yearbook of European Law, advance online publication, August 13, 2024, https://academic.oup.com/yel/article/doi/10.1093/yel/yeae003/7733120 (accessed May 6, 2025). ↑
12. European Parliament and Council, Directive 2011/95/EU (Qualification Directive) of 13 December 2011, https://eur-lex.europa.eu/eli/dir/2011/95/oj/eng (accessed September 3, 2025). ↑
13. Asylum Information Database (AIDA) / European Council on Refugees and Exiles (ECRE), “Safe third country,” Country Report: Greece, Asylum Information Database, https://asylumineurope.org/reports/country/greece/asylum-procedure/the-safe-country-concepts/safe-third-country/#:~:text=Article%2038(4)%20of%20the,asylum%5D%20procedure%20is%20given (accessed September 3, 2025). ↑
14. Berfin Nur Össo, “Unpacking the Safe Third Country Concept in the European Union: B/orders, legal spaces, and asylum in the shadow of externalization,” International Journal of Refugee Law 35, no. 3 (2023): 272–303, https://doi.org/10.1093/ijrl/eead028 (accessed September 3, 2025). ↑
15. Berfin Nur Össo, “Unpacking the Safe Third Country Concept in the European Union: B/orders, legal spaces, and asylum in the shadow of externalization,” International Journal of Refugee Law 35, no. 3 (2023): 272–303, https://doi.org/10.1093/ijrl/eead028 (accessed September 4, 2025). ↑
16. European Court of Human Rights, M.A. v. Cyprus, Application No. 41872/10, judgment of 23 July 2013, HUDOC, https://hudoc.echr.coe.int/eng?i=001-122889 (accessed September 4, 2025). ↑
17. Kelly Petillo, “Strategic aid: How the EU–Lebanon migration deal can work,” European Council on Foreign Relations, Policy Alert, 3 May 2024, https://ecfr.eu/article/strategic-aid-how-the-eu-lebanon-migration-deal-can-work/ (accessed May 6, 2025). ↑
18. Anna Schwarz, “Migration Agreement with Egypt: EU Backing the Wrong Horse,” Heinrich-Böll-Stiftung (Brussels office), 22 March 2024, https://eu.boell.org/en/2024/03/22/migration-agreement-egypt-eu-backing-wrong-horse (accessed September 5, 2025). ↑
19. Lisa O’Carroll, “What is the controversy over the EU migration deal with Tunisia?,” The Guardian, 18 September 2023, https://www.theguardian.com/world/2023/sep/18/what-is-the-controversy-over-the-eu-migration-deal-with-tunisia (accessed September 5, 2025). ↑
20. Infomigrants, “EU Signs Controversial Migration Agreements in Africa,” May 21, 2024, Infomigrants, accessed September 6, 2025, https://www.infomigrants.net/en/post/57175/eu-signs-controversial-migration-agreements-in-africa (accessed September 5, 2025). ↑
21. European Commission, “The European Commission Launches New Migration Partnership with Mauritania,” Press release, March 6, 2024, European Commission, https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1335 (accessed September 4, 2025). ↑
22. European Council on Refugees and Exiles (ECRE), “EU External Partners: Member States Push for Outsourcing of Migration Procedures to Third Countries — EU Signs € 1 Billion Migration Deal with Lebanon — Tunisian Authorities Expel Hundreds of Migrants to Border with Algeria — Migrants Released from Detention in Libya,” ECRE, 10 May 2024 https://ecre.org/eu-external-partners-member-states-push-for-outsourcing-of-migration-procedures-to-third-countries-%E2%80%95-eu-signs-e-1-billion-cash-for-migrants-deal-with-lebanon-%E2%80%95-tunis/ (accessed September 4, 2025). ↑
23. European Council on Refugees and Exiles (ECRE), “ECRE Comments Paper: Regulation establishing a Common Procedure for International Protection in the EU,” ECRE News, 14 November 2024, https://ecre.org/ecre-comments-paper-regulation-establishing-a-common-procedure-for-international-protection-in-the-eu/ (accessed September 7, 2025). ↑
24. Sara Stachelhaus, “EU–Lebanon Deal: Turning a Blind Eye to Reality,” Heinrich-Böll-Stiftung (Brussels office), 16 July 2024, https://eu.boell.org/en/2024/07/16/eu-lebanon-deal-turning-blind-eye-reality (accessed September 7, 2025). ↑
25. Annick Pijnenburg, “Team Europe’s Deal: What’s Wrong with the EU-Tunisia Migration Agreement?,” Verfassungsblog, 21 August 2023, https://verfassungsblog.de/team-europes-deal/ (accessed September 3, 2025). ↑
26. Human Rights Watch, “Tunisia: No Safe Haven for Black African Migrants, Refugees,” Human Rights Watch, 19 July 2023, https://www.hrw.org/news/2023/07/19/tunisia-no-safe-haven-black-african-migrants-refugees (accessed September 3, 2025). ↑
27. InfoMigrants, “Tunisia: Hundreds of Migrants Intercepted at Sea Are Nowhere to Be Found,” InfoMigrants, 2 April 2025, https://www.infomigrants.net/en/post/57175/eu-signs-controversial-migration-agreements-in-africa (accessed September 3, 2025). ↑
28. Human Rights Watch, “I Can’t Go Home, Stay Here, or Leave”: Pushbacks and Pullbacks of Syrian Refugees from Cyprus and Lebanon, September 4, 2024, accessed September 6, 2025, Human Rights Watch, https://www.hrw.org/report/2024/09/04/i-cant-go-home-stay-here-or-leave/pushbacks-and-pullbacks-syrian-refugees-cyprus (accessed September 5, 2025). ↑
29. Alameda Institute, The Political Economy of Anti-Syrian Hate in Post-Crisis Lebanon: A Critical Review, by Ramy Shukr, April 2024, accessed September 6, 2025, PDF, Alameda Institute, https://alameda.institute/wp-content/uploads/2024/09/The-Political-Economy-of-Anti-Syrian-Hate-in-Post-Crisis-Lebanon-V5-EN.pdf (accessed September 5, 2025). ↑
30. UN High Commissioner for Refugees (UNHCR) and Government of Lebanon, 2023 Lebanon Crisis Response Plan (LCRP), published May 2, 2023, UNHCR data portal, accessed September 6, 2025, https://data.unhcr.org/en/documents/details/100389 (accessed September 5, 2025). ↑
31. European Court of Human Rights, M.A. and Z.R. v. Cyprus (Application No. 39090/20), Chamber judgment, October 8, 2024, HUDOC, accessed September 6, 2025, https://hudoc.echr.coe.int/eng?i=001-236141 (accessed September 6, 2025). ↑
32. Milch, Nora. “The Next in Line: Reflections on the EU–Lebanon Migration Deal.” Externalizing Asylum, July 1, 2024. https://externalizingasylum.info/the-next-in-line-reflections-on-the-eu-lebanon-migration-deal/. (accessed September 6, 2025). ↑
33. Kapogianni, Vicky. “Challenging Border Externalisation: Evidentiary Bias and Procedural Violations in M.A. and Z.R. v. Cyprus.” Statewatch, February 11, 2025. https://www.statewatch.org/outsourcing-borders-monitoring-eu-externalisation-policy/bulletin-5/jurisprudence-updates/ (accessed September 5, 2025). ↑
34. European Court of Justice. “Joined Cases C-411/10 and C-493/10: N.S. v United Kingdom and M.E. v Ireland.” Asylum Law Database, December 21, 2011. https://www.asylumlawdatabase.eu/en/content/cjeu-c-411-10-and-c-493-10-joined-cases-ns-v-united-kingdom-and-me-v-ireland (accessed September 5, 2025). ↑
35. Vicini, Giulia. “The Dublin Regulation Between Strasbourg and Luxembourg: Reshaping Non-Refoulement in the Name of Mutual Trust?” European Journal of Legal Studies 8, no. 2 (2015): 51–73. https://cadmus.eui.eu/server/api/core/bitstreams/00d77c03-f959-50ab-9600-93824ae5a8e7/content (accessed September 6, 2025). ↑
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42. European Union. Directive 2013/32/EU of the European Parliament and of the Council of 26 June 2013 on common procedures for granting and withdrawing international protection (Recast). Official Journal of the European Union, L 180 (29 June 2013). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32013L0032 (Accessed May 13, 2025). ↑
43. Decisis. “UK Designation as Safe Third Country for Asylum Seekers Overturned Due to Non-Compliance with EU Law.” Decisis. https://decisis.ie/uk-designation-as-safe-third-country-for-asylum-seekers-overturned-due-to-non-compliance-with-eu-law/. (Accessed May 13, 2025). ↑
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46. O’Riordan, Ellen. “Ireland’s Designation of UK as ‘Safe Third Country’ Is Unlawful, Rules High Court.” Irish Times, March 22, 2024. https://www.irishtimes.com/crime-law/courts/2024/03/22/irelands-declaration-of-uk-as-safe-third-country-unlawful-rules-high-court/. (Accessed May 14, 2025). ↑
47. O’Hanlon, Gillian BL. “High Court: Designation of UK as ‘Safe Third Country’ Ultra Vires and Unlawful.” Irish Legal News, April 9, 2024. https://www.irishlegal.com/articles/high-court-designation-of-uk-as-safe-third-country-ultra-vires-and-unlawful. (Accessed May 14, 2025). ↑
48. European Migration Network (EMN) Ireland. “Legislative Changes to Allow Resumption of Returns to UK, Following High Court Ruling on Designating UK a Safe Third Country.” European Migration Network, March 22, 2024. https://emn.ie/legislative-changes-to-allow-resumption-of-returns-to-uk-following-high-court-ruling-on-designating-uk-a-safe-third-country/. (Accessed May 14, 2025). ↑
49. BreakingNews.ie. “State Loses Appeal over Designation of UK as ‘Safe Third Country’.” BreakingNews.ie, February 26, 2025. https://www.breakingnews.ie/ireland/state-loses-appeal-over-designation-of-uk-as-safe-third-country-1734538.html. (Accessed May 16, 2025). ↑
50. Western People. “State Loses Appeal over Designation of UK as ‘Safe Third Country’.” Western People, February 26, 2025. Accessed September 7, 2025. https://www.westernpeople.ie/state-loses-appeal-over-designation-of-uk-as-safe-third-country_arid-49453.html. (Accessed May 16, 2025). ↑
51. Council of State (Συμβούλιο της Επικρατείας), “Announcements of the President,” 21 Mar. 2025. https://www.adjustice.gr/webcenter/portal/ste/pageste/epikairotita/anakoinwseis-proedrou?centerWidth=65%25&contentID=SNEWS-TEMPLATE1742568296785&leftWidth=0%25&rigthWidth=35%25&showFooter=false&showHeader=true&_adf.ctrl-state=w1v0to6e7_33&_afrLoop=18069787171719108#!%40%40%3F_afrLoop%3D18069787171719108%26centerWidth%3D65%2525%26contentID%3DSNEWS-TEMPLATE1742568296785%26leftWidth%3D0%2525%26rigthWidth%3D35%2525%26showFooter%3Dfalse%26showHeader%3Dtrue%26_adf.ctrl-state%3Dhfw8fe3jr_96 (original in Greek) (Accessed September 6, 2025). ↑
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54. European Union Agency for Asylum (EUAA). Jurisprudence Related to Asylum Pronounced by the Court of Justice of the EU in 2024, Fact Sheet No. 32 (April 2025). https://euaa.europa.eu/sites/default/files/publications/2025-04/Factsheet32_CJEU_jurisprudence_EN.pdf. (Accessed September 8, 2025). ↑
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