EUROPEAN COMMISSION

Brussels, 27.10.2026

SWD(2026) 1038 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on the digitalisation of case management in the area of return, readmission and reintegration, and amending Regulations (EU) 2018/1726, (EU) 2018/1860, (EU) 2019/817 and (EU) 2019/818 of the European Parliament and of the Council

{COM(2026) 1037 final} - {SEC(2026) 1037 final} - {SWD(2026) 1037 final} - {SWD(2026) 1039 final}

Table of contents

1.    Introduction: Political and legal context    

2.    Problem definition    

3.    Why should the EU act?    

4.    Objectives: What is to be achieved?    

5.    What are the available policy options?    

6.    What are the impacts of the policy options?    

7.    How do the options compare?    

8.    Preferred option    

9.    How will actual impacts be monitored and evaluated?    

ANNEX 1: Procedural information    

1.    Lead DG, Decide Planning/CWP references    

2.    Organisation and timing    

3.    Consultation of the RSB    

4.    Evidence, sources and quality    

ANNEX 2: Stakeholder consultation (Synopsis report)    

1.    Consultation methods and stakeholders consulted    

2.    Results of the consultation activities    

ANNEX 3: Who is affected and how?    

ANNEX 4: Analytical methods    

ANNEX 5: Competitiveness check    

1.    Overview of impacts on competitiveness    

2.    Synthetic assessment    

ANNEX 6: Data protection impact assessment for Option 1    

1.    Step 1: Identification of the need for a DPIA    

2.    Step 2: Description of the processing    

3.    Step 3: Consultation process    

4.    Step 4: Assess necessity and proportionality    

5.    Step 5: Identification and assessment of risks    

6.    Step 6: Identify measures to reduce risk    

7.    Potential of artificial intelligence for digital migration management    

ANNEX 7: Detailed impacts of the options    

1.    ‘Baseline scenario’    

2.    Option 1 ‘Partially decentralised option without central EU database’    

3.    Option 2: ‘Partially decentralised option with central EU database’    

4.    Option 3: ‘Centralised system’    

5.    Choice of policy instrument    

ANNEX 8: Overview of policy options    

ANNEX 9: Assessment of financial costs of retained policy options    

1.    Formulas used to estimate the total costs per policy option    

2.    Methodological Approach used to estimate infrastructure costs    

3.    Methodological Approach used to estimate development costs    

4.    Horizontal assumptions across all policy options    

5.    Assumptions specific to each policy section    

6.    Cost items per policy option    

7.    Cost estimation per option    

Glossary

Introduction: Political and legal context

The proper functioning and the sustainability of the European migration and asylum system relies on a comprehensive migration system that manages migration in the long term, which includes the effective return of third country nationals (‘TCNs’) who have no right to stay in the European Union (‘EU’ or ‘Union’).

The Pact on Migration and Asylum ( 1 ) set out the ground for such system and relies on swift and clear processes as well as close and interlinked cooperation between different authorities, within and among Member States, with European Union agencies and with third countries. The adopted Pact legislation forges a seamless link between asylum and return procedures to increase the efficiency and coherence of the asylum and migration system as a whole.

The Pact on Migration and Asylum calls for making full use of the potential of digital systems for more efficient procedures in the field of migration ( 2 ). Digital systems are key enablers for more effective procedures and cooperation, and for reliable data-collection, both crucial to effectively design, enforce and monitor migration policy and rules. They ultimately contribute towards achieving the political goal of establishing a comprehensive migration management system. State-of-the-art digital solutions and processes, as well as planned and possible developments in the next years, increase the potential for improved capabilities and efficiencies. This also fits into the wider EU ambition to find and promote European solutions in the digital age, to simplify processes and to reduce the administrative workload of relevant national and EU authorities.

The Political Guidelines of the President von der Leyen (2024-2029) announced a new common approach on returns, with a new legislative framework to speed up and simplify the process, ensure that returns take place in a dignified manner, digitalise case management and ensure that return decisions are mutually recognised across Europe ( 3 ). The EU Strategy on Voluntary Return and Reintegration ( 4 ) and the Operational Strategy for More Effective Returns of the EU Return Coordinator ( 5 ) reiterated the importance of leveraging the full potential of digital systems to improve efficiency. This point was also mentioned in the Commission Work Programme (‘CWP’) for 2025 and the CWP for 2026 refers to the digitalisation of the return process as a way to ‘continue the work to modernise the common European return system’ and as an initiative ‘with a strong simplification dimension’ ( 6 ). Most recently, the long-term European Asylum and Migration Management Strategy, adopted on 26 January 2026, stressed again that developing digital case management systems in the area of return, reintegration and readmission will further contribute to reducing the administrative workload of national authorities, simplifying and automating processes ( 7 ).

On 7 October 2026, the European Parliament and the Council adopted a regulation establishing a common system for the return of third-country nationals staying illegally in the Union (‘the Return Regulation’) ( 8 ). Return, readmission and reintegration (‘RRR’), are three distinct yet interlinked processes. Their common objective is to ensure that TCNs with no right to stay in the EU leave the EU (‘return’) in a safe and dignified manner. These procedures are characterised by a high level of complexity and diversity of actors involved at local, national and EU level, as well as in third countries.

Despite the ambition of the Return Regulation to further simplify and streamline return rules at EU level, return processes are bound to retain a number of specificities at national level. The Return Regulation envisages digital systems for managing RRR cases of TCNs as one of the components of the common system for returns, considering that digital systems are key to support the effective implementation of return rules, including to enable digital features supporting mandatory mutual recognition of return decisions. The Return Regulation sets out clear legal bases to share and transfer the data necessary to complete RRR processes, in compliance with applicable data protection rules, but does not address the technical means through which such data should be shared and transferred. Detailing these technical means will contribute to ensure that appropriate technical and organisational measures are operational and complied with ( 9 ).

To advance on this, the Commission contracted an external study (the ‘Digitalisation Study’) ( 10 ). The purpose of the Digitalisation Study was twofold: (i) map the existing migration-related systems at EU and Member States’ level and explore a path towards a comprehensive, integrated and digitalised EU migration management system (encompassing other migration processes, such as asylum); (ii) assess the different options to further digitalisation efforts in the specific areas of RRR. All Member States, relevant EU agencies and stakeholders have been consulted via surveys and interviews, at dedicated workshops and other technical meetings.

Following the Digitalisation Study, the Commission is considering options to digitalise case management in the specific areas of RRR as an important step towards the establishment of a comprehensive and digitalised migration management system ( 11 ).

The Commission, EU agencies (eu-LISA, Frontex, European Union Agency for Asylum (‘EUAA’)), and Member States have been making significant investments and progress in the development and implementation of Information Technology (‘IT’) systems in the field of migration management.

However, as regards case management in the area of RRR, the availability, the use and functionalities of IT systems vary greatly between Member States. The existing IT systems for RRR have been developed separately and by different actors, both at EU and national level. The possibilities for further development and data sharing are limited within the current legal frameworks and operational set-up. This results in a fragmented and inefficient digital landscape.

First, on return, all Member States have a return case management system. The structure and content of national return case management systems as well as their overall efficiency vary. To help Member States improve their return case management systems and ensure a minimum level of efficiency, Frontex has developed a Return Case Management Model (‘RECAMAS Model’) in accordance with its mandate (also referred to as the ‘EBCG Regulation’) ( 12 ). The RECAMAS Model is a template (i.e. a document and not an IT system) that provides a basis for Member States to build and set up their own case management systems in similar ways, enabling enhanced cooperation between relevant Member States’ authorities while improving data collection. As part of the Operational Strategy of the EU Return Coordinator and the Common Implementation Plan for the Pact on Migration and Asylum ( 13 ), all Member States should have started the development and implementation of a national system based on the RECAMAS Model in 2024-2025. So far, 26 EU Member States have a return case management system possessing a certain degree of alignment on the RECAMAS Model, but only 12 of them operate a system fully based on the RECAMAS Model.

Second, to enable Member States and third countries to conduct readmission procedures in an efficient, digital and standardised manner, the Commission has supported the development and operation of the existing Readmission Case Management Systems (‘RCMS’), though without specific rules at EU level framing the use of these systems. The systems are physically located in and owned by third countries and require rolling maintenance costs. Currently, there are only six RCMS in place with Armenia, Bangladesh, Georgia, Pakistan, Sri Lanka, and Ukraine. The six RCMS allow for the submission of readmission requests to the third country, as well as monitoring of workflows related to verification and confirmation of nationality, issuance of travel documents and return operations. They are separate systems, each one requiring a different log-in procedure, and do not allow the direct upload of information from Member States’ and EU systems. The Commission plays a leading role in facilitating the connection of willing Member States to the existing RCMS and contributes financially to their proper technical maintenance and operation.

Third, to ensure communication on reintegration cases between return counsellors in Member States and reintegration implementing partners in third countries, the Commission has developed the Reintegration Assistance Tool (‘RIAT’). RIAT is part of the European Migration Network Information Exchange System (‘EMN IES’), established in 2008 ( 14 ). In addition to communication, RIAT is used for financial and administrative handling of cases in the context of various reintegration programmes, including Frontex own EU Reintegration Programme, and data collection. Currently, all EU Member States, Switzerland, Norway, and Iceland, as well as some reintegration partners are connected to RIAT.

Fourth, to support Member States on the return and readmission process, Frontex has developed the Integrated Return Management Application (‘IRMA’), to which all Member States are connected. The development of IRMA is a task of Frontex under its mandate. IRMA is a centralised information system, which allows for secure strategic and operational information exchange on topics such as return statistics, assessment of third country cooperation in the field of readmission, and management of Member States’ needs for forced and voluntary returns, i.e. through its own flight booking system (Frontex Application for Return (‘FAR’)).

Fifth, Frontex is currently developing an off-the-shelf mobile application (i.e. to be placed at the disposal of Member States and customised by them) to facilitate the communication between return authorities and TCNs to be returned. Frontex called it ‘RECAP’.

Sixth, six EU large-scale IT systems (‘EU Information Systems’) relevant for migration purposes are or will be soon in place at EU level. Each system contains an extended list of data of key relevance for the purposes of RRR. In particular:

The European Asylum Dactyloscopy Database ( 15 ) (‘Eurodac’) is the EU’s centralised biometric database, which has been operational since 2003 and is undergoing a major upgrade in 2026. Eurodac helps with the management of asylum applications, by storing and comparing the fingerprint and alphanumeric data of asylum seekers and irregular migrants who have entered a Member State. Eurodac also supports the identification of third-country nationals or stateless persons illegally staying in a Member State.

The Schengen Information System ( 16 ) (‘SIS’), operational since 1995, is an information-sharing platform for border management and internal security. Since March 2023, Member States are also obliged to enter alerts on return in the SIS when a Member State issues a decision to return a TCN.

The Visa Information System ( 17 ) (‘VIS’) supports the implementation of the EU’s common visa policy and facilitation of border checks by allowing the exchange of data on short-term visas (‘Schengen visas’). The revised VIS, expected to enter into operations in 2027, will also store information on long-term visa and residence permit holders.

Since 12 October 2025, the Entry/Exit System ( 18 ) (‘EES’) electronically registers the time and place of entry and exit of TCNs travelling for a short stay and calculates the duration of their authorised stay.

Expected to start operations in the fourth quarter of 2026, the European Travel Information Authorisation System ( 19 ) (‘ETIAS’) will be a pre-travel authorisation system for visa-exempt TCNs.

The European Criminal Records Information System – Third Country Nationals ( 20 ) (‘ECRIS-TCN’) will facilitate the exchange of criminal records information on non-EU citizens and stateless persons across Member States. The system will help judges, prosecutors and other relevant authorities to obtain comprehensive information on criminal history of TCNs, regardless of the Member State where they were previously convicted. ECRIS-TCN is set to start operations in the second quarter of 2026.

All these EU Information Systems will benefit from interoperability components, as established by the Interoperability Regulations ( 21 ). Today, they all work independently, and are queried separately. The interoperability components will make these systems speak to each other, allowing for enhanced information sharing and comparison of available data. The Multiple-Identity Detector (‘MID’) will enable the detection of multiple identities across different EU information systems. For example, a new identity inserted in Eurodac will be automatically compared against the identities already stored in SIS, VIS, ETIAS, EES and ECRIS-TCN. The European Search Portal (‘ESP’) will allow competent authorities to search all these information systems simultaneously. The Shared Biometric Matching Service (‘sBMS’) will enable the search and comparison of biometric data across systems, while the Common Identity Repository (‘CIR’) will store the biometric, identity and travel document data of non-EU nationals available in the EU Information Systems, and the Central Repository for Reporting and Statistics (‘CRRS’). The rollout of interoperability components started in May 2025 when the sBMS entered into operation.

When fully operational, the EU large-scale IT systems will store most of the data required to manage the return and readmission procedures ( 22 ) and thanks to the interoperability of the systems, the future return and readmission IT architecture will be able to articulate and integrate this existing information into the workflows, without duplicating data collection.

Problem definition

What are the problems?

The management of RRR under the current framework is not sufficiently effective to deal with the number of cases. There are often significant delays and, in some instances, it is not possible in the end to carry out the return and, where applicable, to provide reintegration. In 2025, 487 285 TCNs were ordered to leave, and 136 665 TCNs effectively returned to third countries. In 2025, Member States submitted 56 304 readmission requests to third countries. In 2025, the Frontex EU Reintegration Programme (EURP) provided support to approximately 20 000 returnees to 40 countries of origin. While the Return Regulation already addresses many of the underlying problems ( 23 ), it does not cover the digital management of RRR cases.

Figure 1 – Problem tree

Source: Commission

This Section describes the specific problems and problem drivers that can be identified and linked to the overarching question of digitalisation.

The information needed to carry out efficiently RRR is not easily accessible to all relevant authorities

Several categories of data are needed to support the authorities in performing their tasks relating to processing RRR cases in an effective and timely manner. They include ( 24 ): information necessary to establish the identity of the TCN (e.g. surnames, biometric data), information related to the nationality and the travel document(s) of the TCN (e.g. nationality, type of travel document); information related to the TCN’s places of residence, routes travelled, languages spoken and contact details (e.g. phone number); information on residence documents or visas issued by a Member State or a third country; information related to the return operation of the TCN (e.g. flight details); information related to the reintegration of the TCN (e.g. work experience, diplomas); grounds for any return decision taken concerning the TCN, information as to whether the TCN was detained or alternatives to detention were applied to the individual; information related to the criminal records or related to the threat to public policy, public security or national security posed by the TCN; information on vulnerability, health and medical needs of the TCN.

Without this information, the RRR process can often not be completed or becomes lengthy and dependent on the cooperation of the person and/or their country of origin. For instance, a third country will generally not readmit a TCN if its nationality is not first established. The data necessary to swiftly complete RRR processes is often available to other entities/administrations that have interacted with the third country nationals during their migration journey (e.g. data were collected when the TCN asked for a visa, applied for asylum) but not at the ready disposal of the relevant authorities in charge of RRR since it is not shared sufficiently (i) within the same Member State, (ii) between Member States and between Member States and Frontex, and (iii) between Member States or Frontex and third countries.

(i)  As regards the sharing of data within the same Member State, the majority of Member States did not expressly report limitations during the consultations ( 25 ). Yet, Member States also indicated that, in practice, only a few categories of information are widely used for RRR purposes (personal identification data, biometric data, legal status and documentation, and criminal records). Many useful data categories, that when easily available would increase the effectiveness of the process and speed it up, are not used or fully exploited by most Member States, as shown in the Figure below.

Figure 2 - Different data used in Member States to manage RRR cases (n=24) ( 26 )

Source: Digitalisation Study

(ii)  As regards the sharing of data with other Member States and Frontex, the consultation evidenced certain shortcomings (see Table 1 ). A total of 18 Member States reported that there are legal barriers to cross-border data sharing ( 27 ), which in practice means a Member State might need to re-start the RRR process after a TCN crosses an internal border, even if the process was already advanced in another Member State. This is all the more problematic that the number of TCNs subject to a return decision found in a Member State different than the one that issued the return decision amounted to 72 320 in 2025 ( 28 ). Several (15) Member States face challenges in collecting and analysing data and nine Member States complained about data accuracy as the main difficulty ( 29 ). For 10 Member States, significant differences in data quality between Member States undermine the overall efficiency of digital management of RRR processes. 19 Member States consider integration with other information systems as the main challenge ( 30 ). These findings are corroborated by the evaluation of Regulation (EU) 2018/1860 of the European Parliament and of the Council of 28 November 2018 on the Schengen Information Systems for the return of illegally staying TCNs. Users of the system who participated in the focus groups conducted in the context of the SIS study acknowledged that, while the SIS has improved communication between Member States on return cases, shortcomings remain regarding data completeness and quality.

Table 1 - Type of data collected by Member States and shared with other Member States and through EU Information Systems

Source: Digitalisation Study

While much relevant data can be shared via existing and upcoming EU Information Systems (e.g., SIS, Eurodac, EES), there are no channels to exchange some categories of data or data are not stored long enough as they must be deleted before the RRR processes are fully completed. These structural limitations are evident in three distinct scenarios:

·The data has not yet been recorded in the EU Information Systems. For instance, return related data in the SIS can only be exchanged once a return decision is issued. Before the issuance of a return decision, no data is recorded in the SIS, and consequently no information can be shared among Member States, even when operational needs may already exist. For instance, a return case is opened by Member State A in relation to an illegally staying TCN, but this TCN absconds to Member State B before a return decision is issued. Member State A has collected some information that would be useful to Member State B to process the return case, but it is unable to record it in the SIS because there is no return decision and hence no alert in SIS.

·The data has been deleted from the EU Information Systems before the RRR procedures are finalised. For instance, reintegration support may require information exchanges for several years after the person has effectively returned. However, the SIS Return Regulations provide that return alerts must be deleted without delay following the receipt of the confirmation of return ( 31 ).

·The data are queried for purposes not covered by the EU Information Systems’ corresponding legal framework. For instance, Member States need to exchange data for the purpose of reintegration, while such purpose is not referred to by the SIS Regulations.

The insufficient sharing of data within the same Member State, between Member States, and between Member States and Frontex leads to delays in RRR procedures and may prevent their successful completion. On return, the lack of sharing impedes the detection and management of secondary movements (e.g. because the national RECAMAS is not connected to SIS, which prevents a smooth access to return alerts created in the SIS by other Member States). On readmission, this causes delays in the identification procedures (e.g. because the RCMS being used is not connected to the national RECAMAS, which complicates the retrieval of proofs of nationality). On reintegration, the lack of sharing may lead to an accrued risk of reintegration-shopping and double payments as the data on whether a TCN already benefitted from reintegration assistance may not be available (e.g. because the national RECAMAS is not connected to RIAT or because RIAT is not accessing the relevant Eurodac data on reintegration assistance).

(iii)  As regards the sharing of data between Member States or Frontex and third countries, the situation is characterised by inconsistent approaches between Member States and, in several cases, the lack of sharing of necessary data with third countries ( 32 ). The insufficient sharing of data between Member States or Frontex and third countries (due to the lack of sufficiently clear legal bases to share the personal data ( 33 )) prevents in some cases the readmission process from being completed (e.g. when certain information relating to criminal records cannot be shared with the third country of return). The cumbersome sharing of data (due to the lack of RCMS established with the said third countries) may cause delays and hampers the overall readmission process, as the exchange of data with third countries is then done in a less standardised manner (e.g. via emails, postal mails or note verbales).

Excessive administrative burden, delays and inefficient monitoring of cases

Manual intervention in managing RRR cases, such as recording relevant data and uploading documents, places a considerable strain on competent authorities across the EU, contributing to lengthy procedures. Many Member States perceive manual processes as problematic, resulting in increased operational, labour, and administrative costs. 17 Member States identify manual processes that could be, at least partly, automated as a crucial operational challenge ( 34 ).

The lack of automation and system integration leads to a duplication of efforts, higher likelihood of errors and omissions, and administrative burden and costs. These inefficiencies delay procedures, overburden staff, hamper cooperation between Member States and undermine the overall effectiveness of management of RRR processes ( 35 ).

Specific issues include the manual copying of data between national information systems and between national and EU Information Systems (for instance to create return alerts and upload them in the SIS), manual exchanging data with another Member State, and the manual adaptation to new data formats and standards. For instance, one Member State estimated that it takes approximately 30 minutes to create manually an alert on return and upload it into the SIS ( 36 ). Given that there were 464 985 return decisions in the EU in 2024 ( 37 ), this amounts to 29 062 working days ( 38 ) for a total cost of EUR 7 788 499 ( 39 ). Member States also estimated that integrating applications like FAR and RIAT could save 30 minutes per case ( 40 ). With 112 040 effective returns from the EU in 2024 ( 41 ), this could in theory equate to 7 003 working days saved annually, or up to EUR 1 876 670 in labour costs ( 42 ). These figures highlight the significant potential of improved interconnection.

The involvement of multiple stakeholders subject to different requirements leads to complex demands for manual information transmission, further increasing administrative burden. Member States highlighted data entry needs, communication via email, and reliance on physical files as major inefficiencies. The absence of automated data exchange mechanisms further hampers the generation of reliable analytics and statistics. Consequently, these manual processes create significant additional workloads for authorities ( 43 ). Data entry errors occur more without interconnection and automation and undermine system efficiency and data integrity and reduce trust in data shared between Member States. This in turn risks hindering Member States’ willingness to collaborate ( 44 ).

15 Member States identify overall manual data entry as a major operational challenge ( 45 ), leading to bottlenecks, higher labour costs and delays in RRR case management. The perceived limited user-friendliness of EU-level and national systems’ interfaces further exacerbates the issue. The resulting data inaccuracies and correction efforts impede timely decision-making and affect both authorities and TCNs through delays in RRR procedures. National authorities interviewed as part of the Digitalisation Study reported human resource shortages and operational challenges, such as tight deadlines under applicable procedures, which further complicate timely case processing ( 46 ).

The lack of automation also impedes the effective monitoring and follow-up of RRR procedures. In particular, the lack of automation hinders the efforts to ensure that each return decision is enforced and that readmission procedures are timely launched so that the overall return process can be completed. Return decisions are not always meant to be followed up by readmission requests (e.g. in case the TCN is documented, returns voluntarily and by its own means). That being said, in 2024, 464 985 TCNs were ordered to leave ( 47 ) and only 59 593 readmission requests were submitted to third countries ( 48 ). In 2025, 487 285 TCNs were ordered to leave ( 49 ) and only 56 304 readmission requests were submitted to third countries ( 50 ).

More granular and swiftly available statistics are needed

Statistics relating to RRR are first and foremost based on information collected at national level. This information is then transmitted at EU level (for example through the SIS or directly to Eurostat and Frontex), which allows to produce statistics on RRR.

At present, many Member States face significant shortcomings in data collection. As part of the Study, 15 Member States report significant difficulties in collecting and analysing data ( 51 ). Nine Member States consider that inadequate data analytics and reporting are a crucial operational challenge in existing systems. Although 21 Member States indicated that they could generate reports and statistics, real-time monitoring is rarely available or used, with 17 Member States reporting that their national systems do not provide real-time data dashboards. 19 Member States lack the ability to forecast trends related to return decisions ( 52 ). Some Member States report challenges linked to resource-intensive and time-consuming manual collecting of statistical data, which is further exacerbated by the volume of information required for reporting. At the same time, levels of automation remain low and manual corrections are frequently required due to inaccuracies, which undermines the reliability of statistical indicators ( 53 ).

Reliable statistics are crucial to understand migration trends, identify challenges and evaluate measures to effectively manage migration, as well as to enable targeted interventions and efficient resource allocation ( 54 ). Limited access to relevant data at various stages of the migration process makes it difficult to conduct a comprehensive analysis and obstructs effective decision-making ( 55 ). The inability to access reliable data results in inaccurate understanding of the number and status of RRR cases, limits in turn the ability to forecast upcoming trends and leaves authorities ill-prepared to address emerging challenges ( 56 ).

On return, in some Member States, the return decisions that are withdrawn or annulled are not deducted from the total amount of return decisions issued, due to the lack of automation of this task ( 57 ). In other words, the number of annulled or withdrawn return decisions should be systematically collected to deduct them from the total number of return decisions, so as to obtain a more accurate return rate, based on enforceable return decisions. On readmission, inaccurate statistics hamper the ability of national and EU authorities to swiftly and accurately assess the cooperation of third countries on readmission. For instance, the issuance rate (i.e. the number of requests for confirmation of nationality or issuance of travel documents compared to the number of travel documents issued) does not currently give a sufficiently accurate picture of the cooperation of third countries on readmission due to the failure to calculate the number of travel documents issued compared to the number of cases in which the nationality was confirmed. In other words, it would be needed to collect statistics on the number of cases where the nationality was confirmed and the number of cases where travel documents were issued, so as to be able to identify the number of cases where travel documents were not issued while the nationality was confirmed.

On reintegration, RIAT is currently a case-based system (that may include several persons) rather than a person-based system. When a family applies for reintegration support, the case is opened in RIAT using the main applicant data, and the family included in the same case. Consequently, this does not allow a sufficient level of granularity for statistics.

What are the problem drivers?

Incomplete and siloed digitalisation

The current landscape of digitalisation in the field of RRR is characterised by varying levels of progress at both national and EU level. In general, the digitalisation of RRR processes is insufficient and/or fragmented, with excessive manual processing leading to the problems identified in Section 2.1 . The lack of integrated systems and the resulting high degree of manual intervention is a direct problem driver of the excessive administrative burden, due to the need to connect to different systems to process the same RRR case.

Insufficient digitalisation and fragmented digital systems

The availability and use of IT systems to support RRR processes are often limited and differ between Member States. In eight Member States, the management of at least one of the RRR processes is not entirely digitalised ( 58 ). Within a single Member State, in particular if it has a federal structure, several case management systems may be in use to handle RRR cases and may not always be integrated with one another ( 59 ), thereby leading to an insufficient sharing of information and increasing the administrative workload of migration authorities due to the need to switch from one system to another and manually copy the information from or into different systems.

Manual processing creates delays in 12 Member States, increases workload in 15 Member States, and increases the risk of errors and omissions in 15 Member States.

Figure 3 Member States' views on the consequences of manual processing (n=22)

Source: Survey conducted as part of the Digitalisation Study

National case management systems are currently not connected to RIAT and RCMS, creating a digital gap between the management of return and the management of readmission and reintegration. While all Member States are making use of IRMA, no national return system is directly connected to it (a pilot project is ongoing but with only one Member State). Similarly, while all Member States supported by Frontex have access to FAR, only one Member State has a return national system that is directly connected to this Frontex system. FAR is not connected to RCMS and RIAT, despite a clear added value from the point of view of readmission (to organise return operations, including the obtention of landing permits) and reintegration (to identify accurately the starting point of the reintegration programme i.e. the date of effective return, which serves to determine the eligibility of costs).

Return and readmission procedures, except for readmission cases concerning the six third countries with which RCMS are in place, are usually handled through centralised national systems. The provision of reintegration assistance is increasingly managed via an EU-level system (i.e. RIAT).

As explained above under Section 1, Member States use a mix of systems, including (1) national systems based on RECAMAS, (2) EU systems such as RIAT, FAR and IRMA, and (3) RCMS.

Implementation levels and the use of the RECAMAS Model vary significantly across Member States, with 12 Member States using a national case management system built on RECAMAS.

Table 2 – Type of RRR systems in EU Member States (n=27)

Source: Commission, Frontex data and Digitalisation Study.

Many Member States use custom-built national systems that lack interconnection with other systems, with 19 of them employing such systems tailored to national needs without ensuring compatibility with EU systems (including Frontex systems) or other Member States' systems ( 60 ). 19 Member States consider the lack of integration of their systems with other systems to be a major challenge in migration management ( 61 ). 15 Member States identify the lack of integration as a crucial operational challenge ( 62 ).

The absence of a central communication channel or RRR system at EU level complicates information exchange across Member States ( 63 ), as national case management systems are not connected with one another.

The fragmentation of systems used in the case management of RRR is a key reason for the ineffectiveness of the digital management of RRR processes which require effective coordination and timely information exchange at national and EU levels. The fragmentation of systems creates silos that impede effective collaboration and sharing of data. Limited interconnection, isolated national solutions and inconsistent use of shared tools restrict access to critical data for relevant stakeholders. Key information becomes compartmentalised and inaccessible. This in turn leads to limited access to information, miscommunication and duplication of efforts and data. It ultimately undermines the efficiency and coherence of the process, slows it down unnecessarily and hampers the effective monitoring of individual cases across different stages and different Member States ( 64 ).

The insufficient digitalisation and lack of interconnection between relevant systems (i.e. between national return case management systems and other national systems) and between national and EU-level systems (e.g. RIAT and RCMS) increases administrative burdens and prolongs processing times for authorities and TCNs (e.g. need to connect to national RECAMAS to manage return and separately to RCMS to manage readmission).

According to 14 Member States, there is a strong need for the Commission to address inefficiencies in RRR digital management ( 65 ), as the lack of system integration prevents authorities from accessing relevant data when needed and exacerbates information gaps ( 66 ). Due to the lack of integrated systems (e.g. lack of connection between the national RECAMAS and the SIS), some data is currently not processed by all Member States for RRR purposes ( 67 ), while such processing would contribute to more efficient processes and better results. This data would in particular help to speed up the identification process (e.g. by making a better use of biometric data).  

The lack of integrated digital management systems amplifies the current difficulties to accurately, timely and reliably measure the effectiveness and efficiency of RRR processes and the relevance of their results. For instance, the lack of sufficient granularity of statistics is partially due to the fact that national systems cannot currently benefit from the CRRS, as this EU statistical module can only be connected to EU Information Systems and not to national systems. In addition, the lack of integrated systems causes delays in gathering the relevant data and contributes to the fact that some Member States are often late (compared to the applicable legal deadlines ( 68 )) in providing EUROSTAT with the relevant statistics on return.

At the same time, Problem 3 on statistics is also caused by problem drivers going beyond the lack of integrated systems. In particular, the lack of clear definitions at EU level on key concepts such as ‘readmission procedure’ or ‘readmission request’ tends to amplify the problems experienced.

These inefficiencies and ineffectiveness, in particular linked to the lack of integration between systems, contribute to the gap between the number of return decisions and the number of actual returns (‘return rate’). In 2024, in the EU, the return rate was of 24% (464 985 TCNs ordered to leave ( 69 ) and 112 040 effectively returned ( 70 )). In 2025, in the EU, the return rate was of 27% (487 285 TCNs ordered to leave ( 71 ) and 136 665 effectively returned ( 72 )). The SIS return alert has improved communication between Member States, enabling better identification and monitoring of TCNs to be returned. However, a limited number of Member States has a return case management system directly connected to SIS, which complicates the retrieval of necessary data as Member States need to switch from and manually copy data to one system to another. As evidenced in the 2024 thematic Schengen evaluation report 'Bridging national gaps: towards an effective EU return system through common solutions and innovative practices’ ( 73 ), 11 Member States do not have any connection between SIS and RECAMAS, of which five do not foresee it in the near future.

As regards readmission, existing RCMS are used with only six third countries (Armenia, Bangladesh, Georgia, Pakistan, Sri Lanka, and Ukraine). As a result, with many relevant third countries, it is not possible to manage readmission cases digitally. Moreover, they are all independent, requiring a separate log-in, and not connected to EU and Member States systems. This again requires additional time and manual work.

Fragmented governance of IT systems

The involvement of multiple stakeholders in developing and maintaining RRR systems often results in inconsistent practices, standards, and technologies. The fragmented approach complicates collaboration and hinders the efficiency of digital migration management in the field of RRR. The lack of a coherent governance framework further hampers the smooth maintenance and upgrade of IT systems ( 74 ). Responsibilities are often fragmented across institutions, leading to overlapping roles, inconsistent practices, and inefficiencies ( 75 ). In some cases, national authorities share responsibilities with private contractors in charge of maintaining and developing the systems, while at EU level, Frontex manages systems like FAR and IRMA and the Commission manages RIAT. As a result, the allocation of roles and responsibilities under data protection rules (i.e. who acts as controller and as processor) is complex and depends on the specificities of each system. While most Member States report satisfaction with specific system updates ( 76 ), systemic challenges persist.

On RIAT, decisions on functional changes are currently made through the RIAT Taskforce, in which DG HOME, DG JUST and Frontex participate. Member States and reintegration service providers’ needs are collected through the Frontex Post Return and Reintegration Network and RIAT development meetings organised by the Return and Reintegration Facility (‘RRF’), with participation of Member States.

The existing RCMS, have been developed by partner organisations such as IOM and ICMPD. RCMS are located in third countries, owned by them and heavily depend on them for their proper functioning. Some Member States have security and data protection concerns about connecting to RCMS, while third countries have expectations regarding financial contributions from the EU. The ongoing functioning of the RCMS - including system maintenance, development and integration of newly agreed functionalities, and providing user support on both sides - depends entirely on the capabilities and willingness of third countries, thereby constituting a serious governance issue. In the current setup, there is a significant dependence on continued EU funding to maintain and further improve the systems with technological updates and additional functionalities, such as prioritisation of cases or the possibility to search in national identity databases.

Inadequate system functionalities

Even when RRR case management systems are in place and integrated (i.e. the problem driver described in Section 2.2.1 does not occur), the functionalities of these systems are often inadequate and technical functionalities to effectively manage and monitor RRR cases vary across Member States, leading to the problems described in Section 2.1 .

As regards national return case management systems, some features, such as transferring return cases between procedures ( 77 ) (available in 19 Member States) or processing additional data sources for identification (available in 20 Member States), are more common. Other, such as adjusting deadlines (available in three Member States), automatic follow-up of return decisions (available in two Member States), and evaluating returnee cooperation (available in four Member States) are rarely implemented ( 78 ).

Technical challenges in the follow-up of individual return cases across Member States (e.g. due to the lack of single EU identifier or the lack of connection of the national return system to SIS) can lead to multiple cases for the same person due to secondary movements, with 13 Member States reporting this as an issue ( 79 ). 14 Member States highlight the lack of systematic follow-up to return decisions by readmission requests as a major challenge ( 80 ). Unlike other EU Information Systems relevant for migration purposes, the information available in the SIS cannot be copied into the national systems, leaving national authorities with no possibility to import the data into their national return case management systems ( 81 ). This technical limitation is the result of a legal limitation. Consequently, once the alert is deleted, no data on the third-country national remains in the system. This limits the follow-up on processes that extend beyond the moment of effective return and for which certain data categories previously stored in the alert—such as aliases or previously used names—may be useful, including for reintegration purposes. According to the supporting study to the evaluation of Regulation (EU) 2018/1860, only 52% of the Member States have implemented an automatic SIS alert creation functionality in their national case management systems. These limitations also contribute to insufficiently reliable statistics, which do not allow to assess sufficiently satisfactorily the effectiveness of returns.

As regards RCMS, the functionalities differ depending on the third country concerned. In general, RCMS serve as communication tools and repository for evidence. RCMS might also support consular identification interviews through videoconference feature to be embedded in the systems, although this feature is not yet available. Among the most advanced features that an RCMS can provide are the possibilities to (i) upload biometrics through the system to facilitate the identification of the TCN to be returned and (ii) print out the travel documents directly from the system, once readmission requests are accepted by the third country. However, these essential advanced features are not available in all the existing RCMS.

As regards RIAT, which provides a basic infrastructure for managing reintegration cases, the technical functionalities are limited to case management, financial management and monitoring. Users have expressed interest in improvements and enhancements of the system. In particular, the system is now case- rather than person-based, complicating the management of cases, especially when additional support is provided. Furthermore, the system lacks an overview of reintegration programmes available, and information provided to the users of the system is either limited or difficult to find – impairing the user-friendliness of the system. Communication between users with different user roles can be improved. Furthermore, Member States have expressed the desire to link RIAT to FAR and their national return case management systems.

Structural challenges such as insufficient funding (reported by 15 Member States) and insufficient training and support (reported by six Member States) exacerbate these technical inefficiencies ( 82 ).

Lack of sufficiently clear legal bases for the sharing of data and development of IT systems

In accordance with the GDPR and the EUDPR, the processing of personal data may be lawful if necessary for a task carried out in the public interest. This merely indicates that such processing is not prohibited, but subject to the fact that this processing, in the first place, has a legal basis in national or EU law explicitly enabling the authorities to process the data.

Member States can already access the data recorded in EU Information Systems as legal bases are in place in the respective founding regulations of these systems. However, the sharing between Member States of data recorded at national level but not recorded in EU Information Systems often lacks sufficiently clear legal bases. Similarly, the transfer of personal data with third countries for RRR purposes requires a lawful ground for processing, which is often lacking at national and EU level, in particular concerning sensitive personal data.

This leads Member States to refrain from such sharing of information. 13 Member States surveyed refer to a lack of legal framework for the sharing of data as an obstacle for the data sharing ( 83 ) while 10 raise data privacy concerns as another reason for refraining to share the data.

Figure 4 – Member States’ views on reasons why the relevant data is not used for RRR (n=20)

Source: Digitalisation Study

This problem driver is already partially addressed by the Return Regulation, which lays down some clear legal bases for the sharing and transfer of data ( 84 ). However, the Return Regulation does not detail the technical means that may be used to share and transfer such data. In addition, such sharing is currently limited by the legal framework that applies to Frontex ( 85 ).

The lack of sufficiently clear legal framework concerning the technical means and IT systems through which the data could be shared and transferred leads some Member States to refrain from using these systems, and eventually to share the necessary data. This finding applies in particular in the field of readmission where some Member States refrain from using existing RCMS due to data protection concerns stemming from the lack of clear legal framework applicable to these IT systems ( 86 ).

In addition, the development of additional RCMS with new third countries would be facilitated by a clear legal basis, which is currently lacking at EU level.

The lack of clear legal framework on the use of RCMS is also slowing down improvements of the current system, in particular the rationalisation of access, connection with national and EU systems and data storage on the EU side as no relevant EU entity has a clear mandate to store and process such data.

How likely are the problems to persist?

The problems described in Section 2.1 are expected to persist unless further action is taken at national, European, and international levels.

Problem 1 - The information needed to carry out efficiently RRR is not easily accessible to all relevant authorities

To comply with data protection rules, legal bases are needed to enhance interconnection, data sharing and establish new systems. The Pact on Migration and Asylum and the upgraded Eurodac and VIS will contribute to improving data availability, access, exchange and standardisation. The EES will enhance the possibilities to identify overstayers. However, without improved interconnection of digital RRR case management with EU Information Systems (e.g. Eurodac, SIS, EES), the effectiveness of the digital management of RRR processes will remain limited, hindering the EU’s overall migration management efforts. As stated above, the Return Regulation lays down clear legal bases for the sharing and transfer of data, which will contribute to improve the situation. However, the Return Regulation does not detail the technical means that may be used to share and transfer such data, to enhance the interconnection of existing systems, and to develop new systems. The problem identified is therefore expected to persist without intervention.

Problem 2 – Excessive administrative burden, delays and inefficient monitoring of cases

Without a clear and mandatory legal framework, the involved actors would not have sufficient capabilities nor any incentive to develop their system in a manner likely to address the problem identified in Section 2.1.2 . irregular arrivals at Union level are expected to decrease across all the main migratory routes in 2026 compared to 2024, in line with the downward trend already observed in the first half of 2025 ( 87 ). At the same time, it is reasonable to assume that, at least for the foreseeable future, the number of return decisions to be handled by RRR case management systems will remain high in absolute terms. In 2025, 487 285 TCNs were ordered to leave ( 88 ) and 56 304 readmission requests were submitted to third countries ( 89 ). As a result, without intervention, the corresponding administrative burden incurred by national authorities will remain excessive.

Problem 3 - More granular and swiftly statistics are needed

Shortcomings in data collection are expected to persist without intervention as siloed digitalisation and inadequate system functionalities will continue to prevent the automated creation of sufficiently granular statistics. The Pact on Migration and Asylum, the upgraded Eurodac and VIS, and the adoption and implementation of the Return Regulation will contribute to improving data availability, access, exchange and standardisation. The EES will enhance the possibilities to identify overstayers. However, without improved interconnection of digital RRR case management with EU Information Systems (e.g. Eurodac, SIS, EES), the effectiveness of the digital management of RRR processes will remain limited, hindering the EU’s overall migration management efforts

Why should the EU act?

Legal basis

The EU’s legal basis to act is established under 79(2)(c) of the Treaty on the Functioning of the European Union (‘TFEU’). Article 79(2)(c) mandates the European Parliament and the Council to adopt measures in the area of illegal immigration and unauthorised residence, including removal and repatriation of persons residing without authorisation. The development and implementation of efficient digital case management systems in the area of RRR is a means to this end.

Subsidiarity: Necessity of EU action

The identified problems cannot be effectively resolved at national level. Given the magnitude of the fragmentation of the current digital landscape, without EU coordination and an appropriate EU legal framework, Member States will continue developing siloed systems, leading to inefficiencies, uneven digitalisation, and higher costs ( 90 ). Inefficient digital management of RRR processes will hinder the future implementation of common rules on return, resulting in suboptimal levels of returns. This would also affect the proper functioning of the rules of the Pact on Migration and Asylum and have an impact on the Schengen area.

An EU-level intervention is essential to ensure interconnection of relevant IT systems across Member States (including by leveraging EU Information Systems), consistent data exchange, and operational efficiency across Member States. Only a coordinated approach at EU level can address in a coherent manner the cross-border complexities that Member States are currently facing e.g. as regards the insufficient sharing of data between Member States.

Subsidiarity: Added value of EU action

The initiative will generate EU added value because an EU initiative can bring about a common framework at EU level that is expected to enhance data sharing, speed up procedures, reduce administrative burden and enable the creation of more granular statistics. This cannot be achieved in the same way by Member States acting individually. A harmonised digitalised approach to RRR processes at EU level will improve the overall effectiveness of the return system and align with the broader objectives of the Pact on Migration and Asylum. Eventually, coherent digitalisation efforts will support the proper functioning of the Schengen area and the sustainability of the Common European Asylum System.

A unified digital framework will strengthen the EU’s position in negotiations and interactions with third countries and improve the implementation of the 24 EU readmission instruments which provide for uniform procedures. It would contribute to a streamlined approach and coherent expectations in third countries and benefit all Member States.

EU-level efforts will create economies of scale by reducing average costs, as well as avoiding duplication of efforts through system development in silos, and support evidence-based policymaking, including by increasing the reliability of data and statistics. By pooling resources and expertise, the EU can deliver more robust and scalable solutions than Member States acting individually.

Objectives: What is to be achieved?

General objectives

The general objectives are to support the implementation of the rules on RRR laid down in the Return Regulation, and contribute to the implementation of the Pact on Migration and Asylum. Achieving these two objectives will contribute to the proper functioning of the Schengen Area and to the sustainability of the Common European Asylum System.

Working towards a comprehensive and integrated digital case management system at EU and national level to manage RRR processes efficiently, despite the diversity of authorities involved at local, national and EU level, will contribute to these general objectives. Such system would be a first step towards a comprehensive, integrated and digitalised EU migration management system, that would go beyond RRR processes and encompass other migration processes such as asylum. To do so, the initiative pursues several specific objectives.

Specific objectives

Specific Objective 1: enhancing data sharing

The initiative aims to increase data sharing within the same Member State, between Member States and between Member States and Frontex, and between Member States or Frontex and third countries. The objective is to reduce information gaps by ensuring that relevant authorities have access, through appropriate technical means and in compliance with applicable data protection rules, to the information necessary to carry out and monitor RRR processes more efficiently. In particular, all return alerts in SIS should contain the required biometric data.

Specific Objective 2: digitalising, automating and simplifying RRR processes

The initiative aims to foster the digitalisation of RRR processes and remedy the limited functionalities of existing IT systems to ensure that processes and reporting requirements are more digitalised, user-friendly and automated (where relevant through the use of AI, e.g. predictive analytics). National RECAMAS, a future EU Integrated Readmission Case Management System (‘iRCMS’) and RIAT should feature functionalities such as: issuance of a single identifier allocated to each third-country national for whom a case is opened, the automation of case creation upon the ending of a legal stay of a third-country national, a search functionality to identify and detect multiple cases, possibility to monitor deadlines and prioritise cases, possibility for competent authorities and third-country nationals to securely communicate and exchange documents via digital means or possibility to securely exchange information via the Communication Portal. The initiative will support the automated creation of European Return Orders provided for by the Return Regulation and will thereby contribute to the establishment of a mandatory mutual recognition of return decisions.

The initiative will speed up, simplify and streamline processes, increase their transparency and decrease the workload for competent authorities. By doing so, the initiative aims to improve the governance of existing and future IT systems. This streamlined governance will ensure a smooth maintenance and upgrade of the systems, mitigate the risk of developing such systems in silos, ensure data protection compliance by laying down a clear allocation of roles and responsibilities, and provide relevant staff with appropriate and sufficient training.

Specific Objective 3: enabling the creation of accurate statistics

The initiative aims to improve data collection to enable the automated compilation of more accurate and reliable statistics and shorten the timeframe for data collection to better support evidence-based policy and decision-making. In particular, the initiative will enable or simplify the creation of statistics on (i) the number of return decisions issued, (ii) the number of annulled or withdrawn return decisions, (iii) the number of effective returns, (iv) the number of voluntary and forced returns, (v) the readmission statistics on whether the nationality was confirmed, (vi) the number of travel documents issued, and (vii) the number of persons subject to reintegration support per Member State and per third-country of return

What are the available policy options?

Five policy options were considered, with four retained for in-depth assessment, including the baseline scenario. Two options were discarded early (see Section 5.3 ). All options aim to achieve the same objectives (see Section 4.1 ) and address the same problem drivers (see Section 2.2 ) but differ in approach.

Annex 8 provides a comparative overview of the baseline scenario and Policy options 1-3, covering rationale, architecture, technical features, and proposed way forward.

What is the baseline from which options are assessed?

In the baseline scenario, case management systems for RRR are fragmented, operating in silos rather than as an integrated framework. Within the EU, around 40 systems are being used to process RRR cases ( 91 ). Return case management systems exist at national level, but only 12 of them are aligned with the RECAMAS Model. National return case management systems are not connected to one another and RIAT and RCMS are not connected to national return case management systems. In addition, national return systems, RCMS and RIAT are not yet connected to the ESP, IRMA and FAR (apart from one Member State) and cannot be connected to the CRRS. The governance of the IT systems is fragmented.

Competent authorities insufficiently leverage the existing EU Information Systems (e.g. by not making an efficient use of the SIS, as explained under Section 2.1 ). Technical limitations with regard to the EU information systems will persist. For instance, concerning availability of biometric data stored in the SIS, despite the legal obligation to add biometric data to alerts on return, when this data is available at national level, according to eu-LISA statistics on 1 December 2025, only 60.24% of the alerts on return contained biometric data. In 10 Member States the percentage of alerts with biometrics was below 10%. This is explained by the lack of automation in some Member States, a problem which is expected to persist in the baseline scenario.

At the same time, improvements in the field of EU Information Systems are ongoing. Eurodac is undergoing a major upgrade in 2026 and will contain more relevant information for RRR purposes. The EES is fully operational since 10 April 2026 and ETIAS is expected to start operations in the fourth quarter of 2026. Interoperability components are progressively entering into operation (sBMS in 2025) and the ESP is expected to be operational in 2026. The entry into operation of the ESP (and of the MID) will improve Member States’ access to information stored in EU Information Systems and enhance their identity management capabilities.

As detailed in Annex 9, yearly national maintenance costs for case management system are estimated at EUR 3.32 million per Member state.

Option 1 can be visualised as follows ( 92 ):

Figure 5 – Baseline scenario 

Source: Commission

Description of the other policy options

The following sections outline three policy options, which address the problems and objectives identified. All three options would achieve full digitalisation of case management in the area of RRR, by providing the following common features:

·All Member States will need to use a digitalised case management system on RRR.

·Integrated access to one single case management system covering all RRR processes (no need for the user of the system to log off from one system and log on to a different system).

·Interaction and connection with existing and future EU Information Systems, resulting in an enhanced sharing of information between Member States.

·Building case management systems for readmission (iRCMS) and reintegration (RIAT) at EU level. 

·Automation of several processes currently carried out manually, where relevant by leveraging Artificial Intelligence (AI) functionalities, resulting in a substantial simplification and decrease of administrative burden for competent authorities.

·Opening the way for a comprehensive, integrated and digitalised EU migration management system to which additional migration processes could later be added (e.g. screening, asylum), in line with the Pact on Migration and Asylum, and the long-term European Asylum and Migration Management Strategy

Policy option 1 ‘Partially decentralised option without central EU database’

Key features

Under Option 1, the case management system for return will be at national level (‘national RECAMAS’). To ensure consistency and interoperability and with the support of Frontex, national RECAMAS will be based on either (i) the RECAMAS Model developed by Frontex or (ii) an off-the-shelf RECAMAS-based IT system developed by Frontex, in cooperation with eu-LISA, that may be adopted and customised by willing Member States (‘Frontex RECAMAS’), or (iii) based partially on the RECAMAS Model and partially on parts of the Frontex RECAMAS

New integrated case management systems for readmission (iRCMS) and reintegration (RIAT) are developed at EU level (by Frontex, with the support of eu-LISA) and integrated in the national RECAMAS. They will allow to store data from all Member States on readmission and reintegration cases in a centralised manner.

Case management systems query and retrieve information from existing and future EU Information Systems, thanks to functionalities of the European Search Portal. No new EU central database on return is created.

Instead, a Communication Portal developed by eu-LISA (building on existing digital infrastructure e.g. SIRENE, DublinNet, VIS Mail) is used for the communication of additional information that cannot be shared through EU Information Systems (as explained under Section 2.2.1 ).In those cases, the Communication Portal will allow the exchange of this information between Member States. The Communication Portal is connected to each national RECAMAS and the information is directly retrieved from the system and exchanged between national Single Point of Contact (‘SPOC’). The Communication Portal will be a communication channel allowing for structured and non-structured exchanges and running on a secure network.

It will not store data. The system will be owned by eu-LISA and will be connected to all national RECAMAS.

Technical modules for flight booking (via FAR) may be integrated in iRCMS. National RECAMAS, iRCMS and RIAT will be connected to the CRRS to generate more granular statistics. The communication with returnees may occur through ‘RECAP’.

Option 1 can be visualised as follows ( 93 ):

Figure 6 – Infographic for Option 1: ‘Partially decentralised option without central EU database’

Source: Commission

Governance

Member States will develop, maintain and operate their national case management systems on return (national RECAMAS).

Frontex will maintain and update the RECAMAS Model and will develop, in cooperation with eu-LISA, the Frontex RECAMAS that may be adopted and customised by willing Member States. Frontex will also develop ad-hoc off-the-shelf IT solutions (e.g. RECAP) that should be integrated into national RECAMAS.

Frontex will develop and maintain a new EU integrated case management system on readmission (iRCMS) and on reintegration (RIAT), in cooperation with eu-LISA, to be integrated in national RECAMAS. In other words, Frontex will be in charge of the IT management of these systems.

eu-LISA’s support to Frontex will include providing technical advice and expertise on the development and management of the Frontex RECAMAS, iRCMS and RIAT (e.g. during the designing phase or during the procurement phase).

eu-LISA will develop a Communication Portal to allow return authorities to share information that cannot be shared through existing or future EU Information Systems, building on existing infrastructure (e.g. SIRENE, DublinNet, VIS Mail).

Overall, while Member States will still be in charge of their national RECAMAS, Frontex will take a leading role under Option 1 by developing and maintaining the RECAMAS Model, the Frontex RECAMAS, iRCMS and RIAT. As this option does not imply the creation of a new central database, the role of eu-LISA will be more limited. The impact of this governance model on data protection (including the identification of controllers and processors) is described in Section 6.2 (fundamental rights).

Implementation

Option 1 can be implemented by a self-standing EU legislative regulation (i.e. a separate regulation and not only a regulation amending other pieces of EU legislation) containing provisions on the digitalisation of case management of RRR processes and some targeted amendments to existing EU law. The EBCG Regulation will need to be amended. The Interoperability Regulations will have to be amended to ensure that national RECAMAS can make use of the CRRS for statistical purposes. The eu-LISA Regulation ( 94 ) would have to be amended to expand eu-LISA's mandate to entrust the Agency with the development of the Communication Portal. A targeted amendment to the SIS Regulation ( 95 ) will be needed to create the legal base to ensure that the data contained in alerts on return entered under Article 3 of Regulation (EU) 2018/1860 can be kept in national RECAMAS. There is no need to amend the founding regulations of other EU Information Systems.

Policy option 2 ‘Partially decentralised option with central EU database’

Key features

This option has some elements in common with Option 1. The case management system for return is developed at national level (national RECAMAS). As in Option 1, to ensure harmonisation and with the support of Frontex, national RECAMAS will be based on either (i) the RECAMAS Model developed by Frontex or (ii) an off-the-shelf RECAMAS-based IT system, that may be adopted and customised by willing Member States. The case management systems for readmission (iRCMS) and reintegration (RIAT) are developed at EU level (by eu-LISA, with the support of Frontex) and integrated in the national RECAMAS.

Contrary to Option 1, an EU central database dedicated to RRR is created to facilitate the storing and sharing of the relevant data between Member States stored in national RECAMAS, iRCMS and RIAT. For this reason, there is no need for a Communication Portal (as in Option 1). The connection between the EU central database and national RECAMAS is made through a uniform interface. This system would ensure interoperability with existing and future EU Information Systems, leveraging tools like the CRRS, ESP, and other interoperability components (CIR, MID, and sBMS). Unlike Option 1, it allows for the automatic exchange of all data processed in national RECAMAS through the EU central database.

In terms of technical and functional features, the central database enables the introduction of a unique EU case identifier, allowing to identify cases being managed for the same person in different Member States.

Option 2 can be visualised as follows ( 96 ):

Figure 7 – Infographic for Option 2: ‘Partially decentralised option with central EU database’

Source: Commission

Governance

Just as under Option 1, Member States will develop, maintain and operate their national case management systems on return (national RECAMAS). Frontex will maintain and update the RECAMAS Model.

Unlike in Option 1, eu-LISA will develop and maintain the off-the-shelf RECAMAS-based IT system, as well as a new EU integrated case management systems on readmission (iRCMS) and reintegration (RIAT), in cooperation with Frontex, to be integrated in national RECAMAS. eu-LISA will also develop the new EU central database. In other words, eu-LISA will be in charge of the IT management of these systems.

Overall, eu-LISA will take the leading role as the off-the-shelf RECAMAS-based IT system, iRCMS and RIAT will be connected to the EU central database (i.e. a new large-scale IT system) that eu-LISA will develop. The impact of this governance model on data protection (including the identification of controllers and processors) is described in Section 6.3 (fundamental rights).

Implementation

Implementing Option 2 will require a regulation and amendments to the Interoperability Regulation, the founding regulations of all six EU Information Systems (SIS, EES, Eurodac, VIS, ETIAS, ECRIS-TCN), the EBCG Regulation and the eu-LISA Regulation to expand the agencies’ respective mandates, to entrust them with the development of the respective systems.

Policy option 3 ‘Centralised solution’

Key features

Unlike Option 1 and 2, a single case management system is developed at EU level (by eu-LISA) for RRR. This single case management system replaces all national case management systems and integrates the functionalities of RCMS and RIAT. Member States log in to a single EU case management system, which contains all the data relating to RRR. The automatic sharing of relevant data is enabled through the creation of a dedicated EU central database on RRR.

This option replaces national systems with a unified EU case management system, making it mandatory for Member States to use a centralised database for seamless data sharing, removing the need for a dedicated Communication Portal. Accessible via a web platform, the system will leverage the ESP and all other interoperability components (CIR, MID, and sBMS).

Option 3 can be visualised as follows ( 97 ):

Figure 8 – Infographic for Option 3: ‘Centralised system’

Source: Commission

Governance

eu-LISA will develop the new centralised EU case management system and the EU central database, in cooperation with Frontex, which will still be in charge of maintaining and updating the RECAMAS Model. eu-LISA will take the leading role in the development and operational management as the case management system will be inherently linked to the EU central database (i.e. a new large-scale IT system) that eu-LISA will have to develop. The impact of this governance model on data protection (including the identification of controllers and processors) is described in Section 6.4 (fundamental rights).

Implementation

Implementing Option 3 will require a new regulation as well as amendments to the Interoperability Regulations, the founding regulations of all six EU Information Systems, the EBCG Regulation and the eu-LISA Regulation to expand the agencies’ respective mandates and to entrust them with the task to establish the new centralised EU case management system.

Options discarded at an early stage

‘Decentralised option’

During the preparatory process, the option of a decentralised system was considered. This option would involve an EU legislative framework establishing a decentralised national case management system for RRR. Unlike Options 1, 2 and 3, readmission case management systems (RCMS) and reintegration case management systems (RIAT) would also be developed at national level and not at EU level.

The decentralised option can be visualised as follows ( 98 ):

Figure 9 – Infographic for the discarded policy option ‘Decentralised system’

Source: Commission

As in Option 2 and 3, a central database would connect the national case management systems. Member States would continue using their own systems, while the framework would harmonise technical requirements to ensure efficiency, automation, and reliable statistics. This option would also enhance data sharing, particularly with existing EU Information Systems.

Frontex would support this transition by providing guidance, standardised IT solutions, and tools like return applications and identification modules to ensure consistency across Member States. A self-standing Regulation and amendments to existing EU Regulations would be required to establish the legal framework for this decentralised system.

This policy option was discarded based on its lack of coherence, proportionality, effectiveness, and efficiency. This policy option is not coherent with the problems experienced, given their cross-border nature which requires action at EU level, while this option would regress by shifting responsibility for RCMS and RIAT to Member States. This policy option would be disproportionate as it would contradict existing and well-functioning practices whereby RCMS and RIAT are managed at EU level, in line with the principle of subsidiarity.

This policy option is not effective as the time horizon for an EU central database could extend up to seven years due to legal, and technical challenges, making this option ineffective in addressing current problems ( 99 ). This policy option is not efficient as each Member State will have to develop its own RCMS and RIAT, in addition to their national RECAMAS, which will imply some high sunk costs concerning the existing RCMS and RIAT, as these systems will have to remain in place at EU level in the meantime.

These elements make this option inadequate in addressing the current problems, even if this option might imply some progresses compared to the baseline.

Soft law alternatives

Soft law alternatives were considered but discarded at an early stage, given that the problems identified in Section 2 can only be addressed by the establishment of one or several new IT systems, by an improved governance, by an increased interconnection between the different IT systems and by ensuring a minimum level of efficiency of the case management systems.

For instance, the current RECAMAS Model, developed by Frontex, is a non-mandatory blueprint that Member States may decide to implement or not. This is one of the issues explaining the existing fragmentation in case management and information sharing between Member States. EU Information Systems, such as the SIS, while constituting important tools for information sharing in the return area, present technical limitations which do not allow for case management of all RRR processes.

The nature of the existing systems, and the required interconnection between different IT systems to ensure a minimum level of efficiency of the case management systems, would by nature necessitate the adoption of a legal act due to (i) the need for a clear legal basis for processing, under data protection rules, and (ii) the need to amend and broaden the mandate of Frontex and eu-LISA to entrust them with the tasks to develop the new IT systems.

What are the impacts of the policy options?

Annex 7 provides a more detailed presentation of the impacts of the policy options.

The rating of the impact ranges from -5 (very negative in comparison to baseline scenario) to 5 (very positive in comparison to baseline scenario). The baseline scenario is by convention rated as 0.

Policy option 0 ‘Baseline scenario’

Under this option, the Commission would not take any additional action beyond what is already planned or ongoing.

Further details on the assessment of the baseline scenario can be found in Section 1.1 of Annex 7.

Policy option 1 ‘Partially decentralised option without central EU database’

Further information concerning the assessment of the effects of Option 1, as well as its likely impacts are provided in Section 2 of Annex 7.

Policy option 2 ‘Partially decentralised option with central EU database’

Further information concerning the assessment of the effects of Option 2, as well as its likely impacts are provided in Section 3 of Annex 7.

Policy option 3 ‘Centralised solution’

Further details on the assessment of Option 3, as well as its likely impacts are provided in Section 4 of Annex 7.

How do the options compare?

Effectiveness

Efficiency and administrative burden

Table 3 - Overview of costs per stakeholder and policy option

Source: Digitalisation Study/eu-LISA

Coherence

Multi-Criteria Analysis and comparison of timelines

A Multi-Criteria Analysis (‘MCA’) was conducted to compare policy options against the baseline scenario, following the Commission’s Better Regulation Toolbox (Tool #62). The MCA evaluates the effectiveness, efficiency, coherence, and impacts of each option using qualitative ratings supported by quantitative data. The process involved three steps: (1) setting up criteria and an assessment grid, (2) creating an outranking matrix, and (3) assessing results through a permutation matrix.

Table 4 - MCA assessment grid

Based on the multi-criteria analysis, Option 1 is recommended.

The policy options may also be compared from a temporal perspective (see Figure 10 ), based on the key phases and milestones of each policy option.

Figure 10 – Comparisons of indicative timelines between policy options

Source: Digitalisation Study

The figure above is based on the assumption that all policy options are decided upon within two years from the adoption of the Commission’s proposal (i.e. the entry into force of the legislative act), while the technical development and implementation vary across the options. Overall, the timeframe for the development of Policy Option 1 is expected to be shorter than for Policy Options 2 and 3. By building on existing national solutions and the RECAMAS Model developed by Frontex and already implemented fully or partially by many Member States, Option 1 limits the need for complex large-scale IT development and reduces implementation risks. In contrast, Policy Option 2 and 3 would require the design, deployment, and long-term maintenance of more extensive technical systems, a RRR dedicated central database, at EU level, as well as a complex implementation at national level, resulting in longer delivery timelines and higher administrative burden.

The accelerated implementation under Option 1 brings clear financial advantages, as it avoids substantial upfront investment costs and allows Member States to reuse existing infrastructure or adopt a ready-made solution, generating economies of scale. A shorter delivery timeframe is particularly relevant, as it enables faster operational improvements in RRR management, and strengthens Member States’ confidence in the EU’s capacity to provide practical and cost-effective common solutions.

Preferred option

This section summarises the main advantages, disadvantages, impacts, and costs of the preferred policy option.

Main advantages and disadvantages

Option 1 ‘Partially decentralised option without central EU database’ is the preferred option due to its faster deployment, cost-effectiveness, and flexibility. It leverages existing EU and Member State infrastructures, avoiding delays and duplication of data associated with developing a new central database.

While Option 1 is operationally efficient, it has some limitations, such as lower standardisation and continued reliance on decentralised systems for return, which may perpetuate some fragmentation (national RECAMAS will remain national systems).

Table 5 - Overview of main advantages and disadvantages of PO1

Application of the ‘one in, one out’ approach

The ‘one in, one out’ approach refers to the principle whereby each legislative proposal creating new burdens should relieve people and businesses of an equivalent existing burden at EU level in the same policy area. The preferred option is not expected to have any new or removed administrative burden on businesses and citizens.

How will actual impacts be monitored and evaluated?

The implementation of the preferred policy option requires close monitoring to ensure that objectives are met. A high-level monitoring framework, summarised in the table below, outlines the objectives, and the corresponding indicators.

Table 6 – Main indicators for the monitoring the implementation of the preferred policy option

Monitoring data and indicators will be collected and should also capture reductions in administrative burden (e.g. time saving in reporting and case transfer process). Data should ideally be collected in real time and in an automated manner. This data will inform the Commission after the start of operations. AI analytics could also contribute to monitoring and evaluation by identifying patterns in RRR processes.

Evaluations will follow the Commission’s Better Regulation Guidelines (#47 122 ), assessing relevance (e.g. alignment with EU needs), effectiveness (e.g. observed impacts), efficiency (e.g. cost-effectiveness), coherence (e.g. alignment with related interventions), and EU added value (e.g. benefits beyond national efforts). The legal proposal for the preferred policy option must include provisions for monitoring and evaluation to ensure accountability and continuous improvement. The monitoring of the application of the new rules will also be done through the Schengen evaluation and monitoring mechanism.

ANNEX 1: Procedural information

Lead DG, Decide Planning/CWP references

The lead Commission service for this file is DG HOME. The Decide reference for this initiative is PLAN/2024/2663.

This initiative complements the Return Regulation and is linked to the reopening of the EBCG Regulation.

This initiative is part of the Commission Work Programme of 2026.

Organisation and timing

Between 2024 and 2025, a consortium led by EY, commissioned by DG HOME, undertook the assignment titled ‘Study on the way towards a comprehensive, integrated, and digitalised EU migration management system’. The Digitalisation Study carried out an accurate analysis of existing policy issues and included a detailed cost-benefit & feasibility analysis of the different policy options to support the work on the Impact Assessment Report. The reports issued by the contractor (Inception Report, Interim Report, Final Report) were designed to feed into the impact assessment work of the Commission. Several meetings were organised by the contractor to discuss the problem definition, the objectives to be achieved and to develop and evaluate the policy options.

An Interservice Coordination Group (‘ISCG’) on the digitalisation of case management in the area of RRR was set up in January 2025. In addition to the EEAS, SG and HOME, the following DGs are part of the ISCG: BUDG, CONNECT, DIGIT, ENEST, INTPA, JUST, JRC, MENA, SJ and RTD. After each meeting, the members of the ISCG were given the opportunity to comment in writing on a draft version of the impact assessment report and its annexes.

The ISCG was consulted throughout the different steps of the impact assessment: notably on the stakeholder consultation questionnaire and deliverables of the external support study.

The ISCG reviewed and approved the following documents: questionnaires for the stakeholders’ consultation; inception, interim and final reports of the Digitalisation Study; Call for Evidence; Commission’s Impact Assessment Report (i.e. this document).

Throughout the Digitalisation Study, DG HOME engaged directly with stakeholders, organised meetings with experts and other interested parties in order to identify problems and develop options for possible action. The internal and external consultations conducted ensured that the problem definition, baseline scenario, and range of options were grounded in operational realities faced by Member States and EU agencies. The internal and external meetings organised to support the proposal are listed below. For a precise breakdown of and details on the stakeholder consultation, see Annex 2.

The chronology of the main events is as follows:

·7 November 2024: kick-off meeting of the Digitalisation Study (on the way towards a comprehensive, integrated, and digitalised EU migration management system).

·18 December 2024: presentation of the draft inception report of the Digitalisation Study.

·23 January 2025: ISCG meeting to present, discuss and approve the draft Call for Evidence and the draft inception report of the Digitalisation Study.

·26 June 2025: presentation of the draft interim report of the Digitalisation Study, with the attendance of the ISCG.

·30 September 2025: validation workshop with Member States to present and discuss the main findings of the Digitalisation Study.

·7 November 2025 – 5 December 2025: publication of the Call for Evidence.

·13 November 2025: presentation of the draft final report of the Digitalisation Study, with the attendance of the ISCG.

·9 December 2025: meeting with Member States to discuss the policy options identified.

·2 February 2026: ISCG meeting on the draft Impact Assessment Report.

·27 April 2026: ISCG meeting on the draft Impact Assessment Report and on the draft Regulation.

Consultation of the RSB

On 25 February 2026, DG HOME submitted the draft Impact Assessment to the Regulatory Scrutiny Board. The Board issued a positive opinion with reservations on 27 March 2026. The Board’s findings have been addressed in the final version of the impact assessment.

Evidence, sources and quality

In order to gather quantitative and qualitative evidence for the legislative proposal, the Impact Assessment partially relied on the Digitalisation Study conducted by an external contractor (EY) assessing the feasibility and implications of the various options related to the digitalisation of the RRR processes and to support the preparation of the impact assessment report.

The Digitalisation Study assessed the impacts, costs and benefits associated with each policy option, based on a combination of multi-criteria analysis and cost-benefits analysis, in line with the Commission’s Better Regulation Guidelines. The contractor carried out the following consultation activities specifically designed for the purposes of the Digitalisation Study: targeted interviews, targeted written survey, validation workshop.

DG HOME consulted with all relevant stakeholders on the objectives of the initiative and on the identified policy choices. In particular, a specific meeting between the DG HOME and Member States took place on 9 December 2025, as well as several meetings with the ISCG, which constituted a very relevant source of expertise for the preparation of the impact assessment.

The specific evidence sources used are referenced throughout the document whenever they are used. The evidence for the impact assessment report was also based on the following relevant EU public documents and sources:

·Better Regulation Guidelines and the Better Regulation Toolbox.  

·Regulation of the European Parliament and of the Council of 7 October 2026 establishing a common system for the return of third-country nationals staying illegally in the Union, and repealing Directive 2008/115/EC of the European Parliament and of the Council, Council Directive 2001/40/EC and Council Decision 2004/191/EC.

·Directive 2008/115/EC of the European Parliament and of the Council of 16 December 2008 on common standards and procedures in Member States for returning illegally staying third-country nationals. 

·Proposal for a Directive of the European Parliament and of the Council on common standards and procedures in Member States for returning illegally staying third-country nationals (recast) A contribution from the European Commission to the Leaders’ meeting in Salzburg on 19-20 September 2018; COM (2018) 634. 

·Regulation (EU) 2024/1349 of the European Parliament and of the Council of 14 May 2024 establishing a return border procedure and amending Regulation (EU) 2021/1148.  

·Regulation (EU) 2018/1860 of the European Parliament and of the Council of 28 November 2018 on the use of the Schengen Information System for the return of illegally staying third-country nationals. 

·Regulation (EU) 2018/1861 of the European Parliament and of the Council of 28 November 2018 on the establishment, operation and use of the Schengen Information System (SIS) in the field of border checks, and amending the Convention implementing the Schengen Agreement, and amending and repealing Regulation (EC) No 1987/2006. 

·Regulation (EU) 2018/1862 of the European Parliament and of the Council of 28 November 2018 on the establishment, operation and use of the Schengen Information System (SIS) in the field of police cooperation and judicial cooperation in criminal matters, amending and repealing Council Decision 2007/533/JHA, and repealing Regulation (EC) No 1986/2006 of the European Parliament and of the Council and Commission Decision 2010/261/EU. 

·Regulation (EU) 2018/1726 of the European Parliament and of the Council of 14 November 2018 on the European Union Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, Security and Justice (eu-LISA), and amending Regulation (EC) No 1987/2006 and Council Decision 2007/533/JHA and repealing Regulation (EU) No 1077/2011.  

·Regulation (EU) 2019/1896 of the European Parliament and of the Council of 13 November 2019 on the European Border and Coast Guard and repealing Regulations (EU) No 1052/2013 and (EU) 2016/1624. 

·Regulation (EU) 2024/1358 of the European Parliament and of the Council of 14 May 2024 on the establishment of ‘Eurodac’ for the comparison of biometric data in order to effectively apply Regulations (EU) 2024/1351 and (EU) 2024/1350 of the European Parliament and of the Council and Council Directive 2001/55/EC and to identify illegally staying third-country nationals and stateless persons and on requests for the comparison with Eurodac data by Member States’ law enforcement authorities and Europol for law enforcement purposes, amending Regulations (EU) 2018/1240 and (EU) 2019/818 of the European Parliament and of the Council and repealing Regulation (EU) No 603/2013 of the European Parliament and of the Council. 

·Regulation (EU) 2017/2226 of the European Parliament and of the Council of 30 November 2017 establishing an Entry/Exit System (EES) to register entry and exit data and refusal of entry data of third-country nationals crossing the external borders of the Member States and determining the conditions for access to the EES for law enforcement purposes, and amending the Convention implementing the Schengen Agreement and Regulations (EC) No 767/2008 and (EU) No 1077/2011. 

·Regulation (EU) 2018/1240 of the European Parliament and of the Council of 12 September 2018 establishing a European Travel Information and Authorisation System (ETIAS) and amending Regulations (EU) No 1077/2011, (EU) No 515/2014, (EU) 2016/399, (EU) 2016/1624 and (EU) 2017/2226. 

·Regulation (EU) 2019/816 of the European Parliament and of the Council of 17 April 2019 establishing a centralised system for the identification of Member States holding conviction information on third-country nationals and stateless persons (ECRIS-TCN) to supplement the European Criminal Records Information System and amending Regulation (EU) 2018/1726. 

·Regulation (EU) 2019/817 of the European Parliament and of the Council of 20 May 2019 on establishing a framework for interoperability between EU information systems in the field of borders and visa and amending Regulations (EC) No 767/2008, (EU) 2016/399, (EU) 2017/2226, (EU) 2018/1240, (EU) 2018/1726 and (EU) 2018/1861 of the European Parliament and of the Council and Council Decisions 2004/512/EC and 2008/633/JHA. 

·Regulation (EU) 2019/818 of the European Parliament and of the Council of 20 May 2019 on establishing a framework for interoperability between EU information systems in the field of police and judicial cooperation, asylum and migration and amending Regulations (EU) 2018/1726, (EU) 2018/1862 and (EU) 2019/816. 

·Regulation (EC) No 767/2008 of the European Parliament and of the Council of 9 July 2008 concerning the Visa Information System (VIS) and the exchange of data between Member States on short-stay visas (VIS Regulation). 

·Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

·Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC. 

·Regulation (EU) 2016/1953 of the European Parliament and of the Council of 26 October 2016 on the establishment of a European travel document for the return of illegally staying third-country nationals, and repealing the Council Recommendation of 30 November 1994.

·Study on the way towards a comprehensive, integrated and digitalised EU migration management system, HOME-AMIF-TF2-FW-EVA1-4010, ISBN 978-92-68-37351-4; DOI 10.2837/8436041, with Annexes (ISBN 978-92-68-42383-7; DOI 10.2837/0124908). 

·European Commission, Joint Research Centre, Belmonte M., Pingsdorf J., Cortinovis R., Nédée A., Tintori G., Managing irregular migration and return: A framework for understanding and measuring pathways in and out of irregularity in the EU and in selected Member States. Publications Office of the European Union, Luxembourg, 2025, https://data.europa.eu/doi/10.2760/3751767, JRC142752.

·European Commission, Joint Research Centre, Belmonte, M., Sermi, F., Tarchi, D., How to measure the effectiveness of return? Problem definition and alternative definitions of the return and readmission rates, EUR 30491 EN, Publications Office of the European Union, Luxembourg, 2021, ISBN 978-92-76-27075-1, doi:10.2760/200580, JRC122948.

·European Commission, Joint Research Centre, Rosinska A., Drivers of migration: dimensions and indicators. A policy-oriented literature review. Publications Office of the European Union, Luxembourg, 2024, https://data.europa.eu/doi/10.2760/5771973, JRC139459.

·Study supporting the evaluation of Regulation (EU) 2018/1860 of the European Parliament and of the Council of 28 November 2018 on the Schengen Information Systems for the return of illegally staying third-country nationals.

ANNEX 2: Stakeholder consultation (Synopsis report)

No public consultation was organised, as a thorough and broad consultation process was conducted with all relevant stakeholders as part of the ‘Study on the way towards a comprehensive, integrated and digitalised EU migration management system’ (the Digitalisation Study). Such consultation process was complemented by a workshop with Member States, which took place in September 2025, an additional meeting with Member States in December 2025 and the publication of a Call for Evidence published in November 2025.

The synopsis report offers an overview of the consultation process, detailing the stakeholders consulted and key topics explored through each consultation method. Furthermore, it provides a concise summary of the main results from each consultation activity.

Consultation methods and stakeholders consulted

The consultation activities performed included targeted interviews as well as a targeted written survey, validation workshop, ad hoc stakeholder meeting and the publication of a Call for Evidence. Overall, the consultation activities reached around an estimated 180 stakeholders. 11 contributors provided feedback to the Call for Evidence. The objective of the consultations conducted was to better understand the current situation and functioning of migration management, including developments, problems and challenges, as well as to identify the most feasible policy options.

In the following section, information is provided on the type and number of participants in the individual consultation methods.

Targeted interviews

As part of the consultation activities undertaken under the Digitalisation Study, the external contractor conducted a total of 34 targeted interviews with 91 persons. These interviews were designed to gather in-depth qualitative insights from key stakeholders at both EU and national levels, focusing on operational, legal, and policy-related dimensions of EU migration management.

The interviews engaged representatives from four principal stakeholder clusters: the Commission (specifically relevant services of DG HOME, DG JUST and JRC), national authorities from EU Member States and Schengen Associated Countries (‘SACs’), relevant EU agencies and institutions (eu-LISA, Frontex, EDPS), as well as Civil Society Organisations (‘CSOs’), International Organisations (‘IOs’), academia, and reintegration partners. All interviews were conducted virtually between late January and mid-March 2025.

In total, 22 national authorities participated in the targeted interviews, ensuring broad geographic representation across EU Member States and SACs. Additionally, interviews were held with three relevant EU agencies and institutions, four CSOs, IOs and academic institutions and two reintegration partners, alongside three interviews with representatives of the Commission.

The primary aim of the targeted interviews was to elicit stakeholder feedback on the current functioning of the digital management of RRR processes, identify the main challenges encountered, and explore potential avenues for enhancement. Additionally, the interviews sought to better understand which policy options were preferred by stakeholders. Key topics addressed included the current state of digitalisation, interoperability of systems, data protection and privacy concerns, reintegration processes, and the operational needs of frontline actors. An overview of the targeted interviews conducted is presented in the table below.

Table 7 – Overview of targeted interviews

Source: Survey conducted as part of the Study on the way towards a comprehensive, integrated and digitalised EU

Targeted written survey

Three different written surveys targeted at three stakeholder types (i.e. national authorities of EU Member States and SACs, CSOs and IOs) have been conducted in the scope of the Digitalisation Study, involving about 86 respondents.

The survey targeted at national authorities included 107 questions clustered into the following sections: I) the existing situation in Member States and SACs; II) the problem definition; III) why the EU should act; IV) policy objectives; V) policy options; VI) impacts of policy options; and VII) a comparison among policy options.

National respondents include authorities from 27 Member States and SACs (AT, BE, BG, CH, CY, CZ, DE, DK, EE, EL, ES, FI, FR, HR, HU, IE, IT, LT, LU, LV, MT, NL, NO, PL, RO, SE, SI) ( 124 ), mainly entailing national ministries in charge of migration management and asylum (i.e. Ministry of Interior, Ministry of Justice), migration authorities (i.e. Immigration Service Agency), border authorities (i.e. Border Guards, National Police) and a Permanent National Representation to the EU.

The survey targeted at CSOs included 14 questions and answers from three stakeholders providing an overview of the perceptions regarding data protection in the digital management of RRR processes. The survey targeted at IOs gathered answers from stakeholders from two international organisations to 25 questions concerning existing problems, challenges, solutions, and best practices in the area of RRR.

Validation workshop

As part of the Digitalisation Study, a validation online workshop took place on 30 September 2025 with representatives from the Member States, SACs and the Commission. The purpose of the workshop was to validate the findings made during the Digitalisation Study with a broad range of stakeholders, ensuring that results are robust and shared with the broader stakeholder community in RRR.

Nearly all Member States and Schengen-Associated Countries in the workshop were represented, ensuring a broad and sufficiently representative range of contributions. In total, 24 Member States and two SACs participated in the meeting

Stakeholder meeting with Member States

On 9 December 2025, the Commission held a virtual two-hour meeting with representatives from EU Member States, SACs and Frontex. The purpose of the meeting was to present the main policy options under consideration and to give national authorities an opportunity to provide feedback. In total, 22 Member States and 2 SACs participated in the meeting, with 87 registered attendees overall. The Commission presented the specific problems, problem drivers and objectives to be achieved.

Call for Evidence

A Call for Evidence was published and open to feedback from 7 November 2025 to 5 December 2025.

11 contributions were received from seven EU citizens, one international organisation, one non-governmental organisation, one professional organisation and one company/business.

Results of the consultation activities

The following section provides a summary of the main results of the consultation activities.

Targeted interviews

The main findings of the targeted interviews are as follows:

Interviews with national authorities

Current case management systems

Diversity of systems: Various countries utilise distinct case management systems, each tailored to their specific needs but often lacking integration with EU-wide systems like SIS and Eurodac and also other national systems.

Integration challenges: Many national systems are outdated and rely heavily on manual data entry, leading to inefficiencies. Numerous countries highlighted the need for improved interoperability and data sharing between existing systems.

Centralised vs. decentralised approaches: Most interviewees expressed a preference for decentralised or hybrid architectures, citing the impracticality and high costs associated with fully centralised EU systems. Certain Member States emphasised the importance of maintaining national systems while enhancing connectivity with EU frameworks.

Data management and sharing

Data quality issues: Several authorities reported challenges with data accuracy and completeness, often due to individuals providing incorrect information or inconsistencies in biometric data. Some countries noted difficulties in distinguishing between executed return decisions and decisions where individuals are resettled (i.e. residing in another EU Member State where they have the right to stay), which leads to confusion and affects the accuracy of data.

Limited data sharing: Data sharing with other Member States and EU systems is often conducted via email or manual processes, which can hinder timely decision-making. Several countries highlighted the need for better integration with EU systems to facilitate more efficient communication.

Unique identifiers: The implementation of unique identifiers for tracking individuals through the return process was noted as a critical improvement needed in several national systems.

Existing challenges in digital migration management

Fragmented IT systems: It was often noted that the fragmented IT systems across EU Member States hinder coherence and efficiency in RRR processes, complicating information sharing and case management. This lack of interoperability leads to delays and difficulties in monitoring returnees across borders.

Communication with third countries: Numerous interviewees highlighted communication difficulties with the embassies of third countries as a major obstacle to effective RRR processes. Some Member States specifically noted the necessity for a centralised communication channel to facilitate smoother interactions.

Resource constraints: Several national authorities reported limited resources, specifically human resources for managing return and reintegration cases, which contributes to delays and inefficiencies in digital processes. The need for enhanced support from organisations such as the IOM was often highlighted to improve the capacity for effective digital management of RRR cases.

Future outlook and recommendations

Need for automation: Interviewees from multiple countries emphasised the importance of automating processes to enhance efficiency and reduce manual data entry. This includes integrating flight booking systems and improving reporting capabilities.

Interoperability with EU systems: There is a strong desire for enhanced interoperability with EU systems, particularly SIS and Eurodac, to facilitate better data sharing and improve the overall effectiveness of return management.

Political and legal considerations: The feasibility of implementing new systems is often hindered by political and legal constraints, including varying national jurisdictions, different agencies involved taking responsibility, and the need for mutual recognition of return decisions among Member States.

Interviews with relevant EU agencies

Roles and responsibilities

Need for clarity: The interviewees underlined the lack of clarity and coherence among various authorities involved in RRR processes. This ambiguity often leads to overlaps in duties and gaps in accountability, resulting in inefficiencies and delays in case management.

Integration and coordination: Desires were expressed for a more integrated approach to defining functions within the system, suggesting that a unified framework could facilitate better coordination and resource allocation. This would not only enhance operational efficiency but also foster a shared understanding of objectives among all stakeholders involved in the return and reintegration processes.

Challenges in current systems

Fragmentation and silos: Existing EU Information Systems operate in silos, leading to inconsistencies in data management and quality. This fragmentation complicates the identification and monitoring of individuals across different systems.

Data quality issues: Varying data quality across systems poses challenges for accurate matching of individuals, impacting the effectiveness of RRR efforts.

Digitalisation efforts

Need for centralised solutions: A centralised approach to identity management and data sharing is recommended by the interviewed agencies to improve efficiency and compliance. While a hybrid model may also be feasible, a unified system is preferred for better coordination.

Interoperability: Enhancing interoperability among existing systems is crucial for effective migration management. The ESP could facilitate this by allowing queries across all systems in line with access rights.

Data protection and rights

Right to information: TCNs often lack sufficient information regarding how their data is handled, which undermines their rights. Some agencies emphasised the importance of timely and clear communication of rights to data subjects.

Legal framework: The existing data protection framework, including the EUDPR, is considered robust but there is a growing gap between legal obligations and technical implementation, necessitating better guidelines and training for staff.

Recommendations for improvement

Enhanced training: There is a need for improved training for staff on data protection rights and the use of digital tools to ensure compliance and effective communication with data subjects.

M&E: Developing a robust Monitoring and Evaluation (‘M&E’) framework for return practices in the digital context is essential to refine existing programmes and ensure effective implementation across Member States.

Future considerations

Identity management: Addressing identity management within migration systems is critical for data protection and the overall effectiveness of migration management processes.

Capacity for development: Agencies like eu-LISA face challenges in meeting development timelines due to their current workload, highlighting the need for integrated planning and resource allocation. Other such as Frontex noted that the lack of a clear legal basis and established timeframe for digitalisation initiatives makes it difficult to set concrete goals and priorities.

Interviews with reintegration partners

Challenges

Inflexibility of RIAT: Some reintegration partners highlighted the inflexibility of the RIAT system, particularly regarding the inability to update submitted information once it has been approved. This limitation can hinder effective case management and responsiveness to individual needs.

Data quality issues: Challenges related to data quality were noted, including missing or incorrect contact details for returnees, which complicate communication and support efforts. The quality of data varies across Member States, impacting the overall effectiveness of reintegration preparations.

Communication and collaboration

Effective communication: Some interviewees reported excellent communication through the RIAT system, contributing to their good reputation among partnering Member States. Regular training for staff ensures effective service delivery and collaboration.

Bilateral agreements: Reintegration partners collaborate with various Non-Governmental Organisations (‘NGOs’) and government entities, enhancing the reintegration process through established partnerships and shared resources.

Recommendations for improvement

Enhancements to RIAT:

·Enhanced visibility for post-arrival packages and the introduction of colour coding for case management. 

·Mandatory uploads of travel documents and contact details to ensure comprehensive case information.

·Allowing users to edit arrival dates and re-upload documents to maintain accurate records.

Consultation with service providers: It was emphasised that service providers like Caritas and ETTC should be consulted when implementing digital strategies for returnees, given their practical experience and insights into the challenges faced.

Interviews with CSOs, IOs, academia

Fundamental rights and data protection

Emphasis on rights: All organisations highlighted the importance of protecting fundamental rights within migration management, particularly concerning return processes. There is a consensus that migration policies must not compromise the dignity and rights of TCNs.

Data protection concerns: Some CSOs raised significant concerns regarding excessive data collection that often lacks relevance to return decisions. They emphasised the necessity for compliance with the GDPR and the implementation of robust safeguards to protect individuals' data. Other interviewees echoed these concerns, advocating for transparency in data collection practices and the need to inform TCNs about the data being collected and its intended use.

Data sharing and interoperability

Need for improved infrastructure: The importance of strengthening data-sharing infrastructure and improving interoperability between systems was emphasised only by some interviewees, while all interviewees pointed out that common rules on data collection are important. Enhanced data sharing is seen as crucial for effective return processes and better coordination among Member States. 

One interviewee outlined that the central solutions of data are easier to implement, as only one authority will be responsible for the management afterwards. In addition, a centralisation of safeguarding rules on data collection and storage was considered an advantage.

In the interviews, the necessity for investment in registration infrastructure to facilitate the identification and documentation of migrants was highlighted.

Outdated technology: Interviewees from an IO pointed out that with regard to the current systems used (e.g. RCMS), the technology provided is somewhat outdated. Often the systems used are still legacy systems. The question of where the data should be stored for RCMS may prevent further developments of the system.

Many of the databases in the Member States do not capture all relevant data or do not allow for sufficient monitoring of cases.

Fragmentation

High levels of fragmentation: Some interviewees confirmed the finding that the current infrastructure is highly fragmented, complicating infrastructure between the different Member States.

In this context it was mentioned that also the involved actors are highly fragmented.

Policy recommendations

Long-term development investments: Some interviewees recommended that the EU invest in the long-term digital development of third countries to foster cooperation on return and reintegration.

Basic data principles: Interviewees reiterated that basic principles such as data minimisation and transparency should be respected in order to ensure a lawful collection of data.

Cooperation: Interviewees confirmed that it is needed that Member States start to cooperate more strongly in the field of digital migration management.

Targeted written survey

Existing situation

The survey targeted at national authorities provides information regarding the current system in place to manage RRR, including the type of available data and the extent to which they are shared across countries.

Firstly, the approach to managing RRR differs among Member States. Indeed, seven national authorities use an integrated case management system (i.e. one single system treating RRR) while seven reported using separate systems for RRR and nine national authorities highlighted the use of methods not standardised across countries. Only one national authority stated that no specific system is in place.

In addition, the digital management of RRR cases varies with regard to the practical implementation. Indeed, according to survey results, return cases are primarily handled through centralised national systems, with limited reliance on EU-level systems. In a similar manner, readmission cases are mainly managed through a centralised system, with only few countries relying on decentralised local systems. Conversely, reintegration is mainly managed through EU-level systems, followed by centralised national systems, and with limited use of manual and decentralised local systems.

There are various systems designed to manage RRR, ranging from custom-built national solutions, created by individual Member States, to systems, such as EU-level systems which operate across multiple countries.

The survey gathered information about the type of data that are collected by Member States to manage return, reintegration and readmission and the type of data that is shared across Member States and through EU systems. In terms of data collected and used by countries to manage RRR, the majority of national authorities responding to the survey stated that they collect and use the following data: legal status and documentation (24 national authorities), personal identification data (23 national authorities), criminal records (23 national authorities), biometric data (22 national authorities), health and medical records (18 national authorities), travel history and entry/exit record (18 national authorities). However, evidence collected through the survey presents a mixed picture regarding the alignment between the data collected at the national level for RRR and the data shared with other countries and with EU systems. As shown in the table below, all Member States that collect and use personal and biometric data for RRR tend to share it with other Member States and EU systems. Similarly, half, or more than half of national authorities collecting legal status and travel history data share it as well. On the other hand, less than half of the Member States collecting and using information of criminal and medical records tend to share this information with other EU Member States and EU systems, and only few Member States gathering data on the social and economic background of TCNs share it.

Table 8 - Type of data collected by Member States and shared among national and EU systems

Source: Study on the way towards a comprehensive, integrated and digitalised EU

Moreover, the large majority (18 national authorities) of survey respondents considered the available data sufficient for managing cases, with six reporting limitations stemming from data protection regulations, lack of access to social and private data, and challenges in verifying nationality when individuals do not cooperate.

Also, the survey results remarked that some data are available but not yet used due to the lack of technical capability, data protection and privacy concerns, and insufficient legal frameworks.

Finally, three CSOs out of three warned against the risk of low data protection which is undermined by data breaches and limited effectiveness of data protection regulations among CSOs, while the IO stressed inefficient data sharing mechanisms with regard to readmission, and a lack of standardised procedures for what concerns both data management systems for readmission and reintegration programmes.

In addition, the participant in the IO survey highlighted a substantial inconsistency in data formats in the RCMS as well as data entry errors hindering data accuracy.

Problem definition

Survey results provide a picture of the overarching, technical and operational challenges faced by national authorities in the management of their RRR systems.

As concerns overarching challenges, most national authorities responding to the survey have highlighted:

·Legal barriers to cross-border data sharing (18 national authorities).

·Complex and fragmented legal frameworks across Member States (18 national authorities).

·Strict data protection regulations limiting data sharing and processing (18 national authorities).

·Delays caused by bureaucratic complexities in implementation (17 national authorities).

·Lack of standardised digital tools across Member States (16 national authorities).

·Difficulties in integrating digital systems with existing administrative frameworks (15 national authorities).

·Challenges in data collection and analysis (15 national authorities).

·Insufficient funding for relevant initiatives aiming at strengthening the digitalisation of processes (15 national authorities).

·Limited availability of skilled talent and expertise (15 national authorities).

·Complexity in complying with national and EU-level regulations (15 national authorities).

·Legal constraints on cross-border data transfers (18 national authorities).

·Data protection and privacy and security concerns (13 national authorities).

The majority of national authorities responding to the survey also remarked some existing technical challenges:

·Lack of interoperability between different digital systems and platforms (16 national authorities).

·Issues in ensuring secure communication and data exchange (14 national authorities).

·Difficulties in scaling systems to handle increasing volumes of data and users (13 national authorities).

·Difficulties in integrating automation and workflow tools into existing systems (13 national authorities).

Moreover, with respect to challenges connected to interoperability of systems to manage RRR, 19 national authorities further confirmed that integration with other systems represents one of the main challenges faced with current systems, along with data completeness (15 national authorities).

Overall, major operational challenges seem to be related to manual processes and the limited degree of automatisation. Indeed, among operational challenges faced with the use of existing systems, national authorities responding to the survey underscored manual processes that could be automated (17 national authorities). Moreover, while no main operational challenges are identified with regard to returns and reintegration, 1 national authority remarked that the main challenge related to readmission stands in the limited automatic and systematic follow up of a return decision by a readmission request.

In addition, the use of manual processes over automated ones leads to increased costs according to national authorities responding to the survey. Indeed, 17 national authorities agreed that the lack of automated processes requiring manual intervention, the need for manual data entry and verification, as well as manual case management processes, lead correspondingly to higher operational, labour and administrative costs. In a similar manner, the need for manual data entry and processing increases the workload of officers and enhances the likelihood of errors and omissions according to 15 national authorities responding to the survey.

Finally, the survey highlighted several other challenges, including insufficient funding for the development and maintenance of digital tools (with 15 national authorities agreeing or slightly agreeing), budget constraints limiting investment in new technologies (with 16 national authorities agreeing or slightly agreeing), securing long-term financial support for digital initiative (with 16 national authorities agreeing or slightly agreeing), and organisational culture and practices differences across different Member States (with 15 national authorities agreeing or slightly agreeing). In addition, three out of three CSOs identified potential violations of privacy and discrimination as another severe challenge.

Two participants in the IO survey highlighted some challenges regarding the functioning of the RCMS, including user interface complexities, frequent technical issues and slow system performance, resistance to change, as well as issues with data accuracy and consistency, in terms of data entry errors and data fragmentation.

Why should the EU act

15 responding Member States are convinced that existing challenges can be effectively solved by individual Member States, with only one feeling that national efforts would suffice. However, when asked about the necessity for the Commission to intervene, 18 national authorities indicated a ‘large’ (14) or ‘very large’ (4) need for action, highlighting the Commission's critical role in facilitating cooperation and standardisation.

Moreover, when inquired about the need for EU action, respondents showed a strong belief that coordinated EU-level action would enhance data sharing and improve communication with third countries (14 national authorities), while they agreed that a more united and coherent digital approach of the EU in its communications with third countries for readmission cooperation’s purposes is likely to improve the effectiveness of the readmission process as a whole (12 national authorities) and that digital challenges hinder the overall functioning of the EU system governing RRR (11 national authorities).

In addition, the participants in the IO survey also highlighted the need to improve communication tools with a view to use digital systems. The participants stressed the need to perform comprehensive access control in order to enhance data security in readmission processes, the need for standardised guidelines and procedures for reintegration programmes and, lastly, the need to enhance interoperability among various systems.

Policy objectives

The majority of Member States surveyed highlighted that a new EU action on the digitalisation of migration management shall achieve the following policy objectives:

·To speed up procedures and decrease the workload for the competent authorities (indicated by 22 respondents of high or very high importance).

·To increase the data sharing between existing and future IT systems on RRR and other relevant IT systems such as relevant EU Information Systems (indicated by 21 respondents of high or very high importance).

·To conduct RRR processes more efficiently (indicated by 21 respondents of high or very high importance).

·To ensure that processes and reporting requirements are more digitalised, user-friendly, and automated (indicated by 20 national authorities).

·To ensure access to the necessary data (indicated by 20 national authorities).

In addition, three out of three CSOs opposed the idea of having an integrated case management system at EU level, which, on the opposite, is supported by the participants in the IO survey together with the need to introduce standardised reintegration protocols and interoperable systems.

Policy options

Respondents assessed several procedural features based on their importance in addressing current and future challenges. Notably, 15 national authorities emphasised the importance of processing additional data sources for identification and decision-making, while 13 respondents accounted automatic and systematic follow up of return decisions by a readmission request as important or very important. Moreover, the integration of a flight booking system was rated as important or very important by 12 respondents, together with the extraction of departure obligation lists and the adjustment of deadlines that may differ (e.g. between different types of readmission procedures) deemed important or very important by 10. Lastly, the ability to start a return case under one procedure and later transfer it to another was accounted as important or very important by nine respondents.

The survey also assessed the importance of horizontal features critical for effective management. Generating reports and statistics, as well as M&E and user-friendliness of the interface for case handlers was rated as of high or very high importance by 16 and 15 national authorities correspondingly. Furthermore, varying access rights (i.e. identity management) for different users depending on the systems or modules was rated as important or very important by 14 respondents, while monitoring real-time data dashboard on reintegration statistics and managing multiple cases for the same person in different Member States following secondary movements were rated by 13 authorities as of high or very high importance.

When inquired about the most crucial improvements for enhancing management, the introduction of an integrated case management system was favoured by 11 national authorities. Increased funding and resources were also highlighted by eight, indicating a consensus on the need for better coordination and resource allocation to support return management efforts. Other options, such as better coordination between national and EU levels and enhanced M&E, received minimal support, with only one each.

In terms of design features for an integrated case management system, interoperability with existing systems emerged as the most critical aspect, with 18 national authorities emphasising its importance. Additionally, a modular and flexible architecture was favoured by 15 national authorities, suggesting a preference for adaptable systems that can evolve with changing requirements. User-friendly interface was also recognised as important by 14 respondents.

Furthermore, the survey explored the potential of emerging technologies in enhancing case management systems. Biometric systems were identified as promising advancements by 17 national authorities, while artificial intelligence and machine learning received support from 14 respondents. These technologies were seen as vital for improving identification and data analysis processes, which are essential for effective return management.

Finally, two participants in the IO survey indicated automated workflow management as the most effective digital solution to streamline the readmission process, coupled with the carry out of a comprehensive training for user to enable them to effectively use the systems. With regard to reintegration, case tracking management would benefit the most from an increased digitalisation of the system, including the introduction of a real-time data dashboard, stressing the need to combat resistance to change as the most significant barrier to implementing a digital case management system for reintegration.

Validation workshop

Problem and objectives

Participants were presented the problem definition and objectives pursued. Two participants flagged that the limited data sharing and completeness outlined as problem drivers will be difficult to resolve, as Member States would need to first agree upon a shared definition for the data. This is considered to involve significant workload that requires sufficient resources and time. Overall, feedback on both aspects was rather positive.

Table on the summary of main components of the policy options

An overview on the main components of the policy options was presented. Among the most important points discussed were:

·The roles of Frontex and eu-LISA in developing and implementing the technical infrastructure.

·The intrusiveness of the policy options: Some respondents enquired whether policy option 1 can be considered the least intrusive among the policy options presented. One stakeholder indicated that policy option 1 was their preferred policy option.

·The availability of public funding from the Commission: Multiple participants enquired whether public funding will be made available by the Commission to implement the new system (e.g. under AMIF).

·The use of Artificial Intelligence (AI) and other digital, innovative solutions.

SWOT analyses

Policy option 1: Partially decentralised option without central EU database

Among the main strengths discussed were in particular:

·The quick implementation time.

·Building upon already existing solutions in the Member States.

·The flexibility to adapt the system to the single needs of individual Member States.

·The cost-effectiveness.

·The low invasiveness.

Among the main weaknesses discussed were in particular:

·The higher degree of manual work by Member States without a central database available.

·The differing levels of ability and expertise in implementation of Member States.

·Limited possibilities to exchange data.

·The fact that administrative burden is not necessarily reduced.

Among the main opportunities discussed were in particular:

·The opportunity for Member States to exchange data via RIAT and RCMS.

Among the main threats discussed were in particular:

·Difficulties in ensuring that all Member States use the system correctly across the Union.

·The use of the communication channel might not be as intended.

·The danger of double registration, which might not be fully mitigated through the policy option.

Policy option 2: Partially decentralised option with central EU database

Among the main strengths discussed were in particular:

·The higher data quality (in particular accuracy).

·Faster exchange of relevant information.

Among the main weaknesses discussed were in particular:

·The very long implementation time.

·The costs are expected to be quite high.

·Data harmonisation might be difficult and data definitions must be harmonised.

Among the main opportunities discussed were in particular:

·A reduction of the risk to handle cases in parallel.

·Frontex could be included under this option with a role related to IT development.

Among the main threats discussed were in particular:

·eu-LISA might be one organisation too much in managing return and would lead to additional confusion.

·‘Weaker’ national set-ups are not necessarily changed.

·The technical implementation needs to be fully uniform.

Policy option 3: Centralised solution

Among the main strengths discussed were in particular:

·Very fast, real-time exchange of data.

·Better time savings for users when they use a single platform.

·A better harmonisation of the European system.

·The existence of a central service provider (e.g. eu-LISA), which could enhance interoperability.

Among the main weaknesses discussed were in particular:

·The very long implementation time.

·The high sunk costs related to this option, as national systems would continue to be used until they will be abandoned.

·Data harmonisation might be difficult and data definitions must be harmonised.

·The reduction of flexibility to changes.

·The fact that one system might not fit everyone’s interests and needs.

There were no main opportunities mentioned by the participants.

Among the main threats discussed were in particular:

·The risk that all Member States would be equally affected by a system downtime.

·The threat that national specifications might not be considered sufficiently in the system.

·The lack of certain elements linked to asylum such as Dublin.

·The loss of very advanced systems in some Member States.

Stakeholder meeting with Member States

Participants were presented the three core problems affecting the current RRR systems, the problem drivers, and the objectives of the digitalisation legislative proposal. No Member State objected to the Commission’s understanding of these problems and objectives.

Based on these elements, the Commission recalled the three possible policy options and opened the floor to participants for questions and comments. During the discussion, several representatives posed questions and shared observations. All Member States who took the floor supported Option 1 and no Member State objected to the presentation of Option 1 as the most beneficial one. More specifically, one participant asked whether, under Policy Option 1, it would be possible to automatically retrieve data from iRCMS and RIAT without having to request it from another Member State. Another representative sought clarification on the legislative proposal’s ambition regarding interoperability, in particular whether the future proposal would foresee integration with environments such as FAR and IRMA. A question was raised on the two possible development pathways under Policy Option 1—using a system based on the RECAMAS Model or an off-the-shelf reference implementation.

Furthermore, one Member State referred to the possible relationship between the digitalisation legislative proposal, Article 40 of the Return Regulation, and the forthcoming changes to the Frontex mandate. Questions were also raised regarding integration with the ESP and the usability of the communication channel. Finally, concerns were expressed about the extent of possible changes to SIS and whether the new communication channel would replace the existing consultation requirements under the SIS Regulation.

Call for Evidence

General concerns relating to migration and the role of the EU were raised. Harmonised digitalisation was depicted by some respondents as having the potential to facilitate exchange of information between the EU and third countries and between Member States, as well as to ease the return process and keep the detention period as short as possible. The importance of recording biometric data was underlined by one contributor. The importance to strictly adhere to fundamental rights, including data protection (e.g. storage limitation, purpose limitation, transparency), was underlined by several contributors.

ANNEX 3: Who is affected and how?

The purpose of this section is to support the analysis provided in Section 6 by providing an overview of the costs and benefits (as much as possible in quantitative terms), as well as the application of the ‘one in, one out’ approach and an overview of relevant Sustainable Development Goals.

Overview of who is affected and how

Table 9 - Overview of benefits (total for all provisions) – Preferred Option

Summary of costs and benefits

As a tool for assessing the costs and benefits, the Commission used the relevant parts of the Commission’s Better Regulation Guidelines’ Toolbox. This concerns in particular Chapter 8 ‘Methodologies for analysing impacts in impact assessments, evaluations and fitness checks’, tools #56 (‘Typology of costs and benefits’), #57 (‘Methods to assess costs and benefits’), #58 (‘EU Standard Cost Model’) and #59 (‘Cost estimates and the One In, One Out approach).

An overview on the costs is given in the following tables. Table 10 provides an overview of the overall costs for the preferred policy option. The estimates include one-off and recurrent costs across the first six years after entry into operation.

Table 10 - Overview on the general costs (in EURm)

Source: Digitalisation Study

Table 11- Overview of costs – Preferred option

Table 12 – Application of the ‘one in, one out’ approach – Preferred option

No costs stemming from new or removed administrative burdens (i.e. from the application of the ‘one in, one out’ approach) have been identified.

Relevant sustainable development goals

Table 13 - Overview of relevant Sustainable Development Goals – Preferred Option

ANNEX 4: Analytical methods

The work focused on assessing the feasibility and impacts of policy options. For this purpose, an external study (the Digitalisation Study) was procured to gather the relevant data and support the impact assessment.

The Commission’s impact assessment methodology served to structure and guide the analyses informing policy design. It illustrated the logical reasoning that connected the problem (including subsidiarity issues), its underlying root causes, the objectives of a policy intervention, and a range of policy options to address the problem. It also assessed the likely impacts of the options, who would be affected by them, and how.

The text below highlights how the specific impact assessment questions were addressed (as per the Better Regulation Guidelines) and provides an overview of the key methodologies (highlighted in blue).

Table 14 - Overview of the analytical approach

ANNEX 5: Competitiveness check

Overview of impacts on competitiveness

Synthetic assessment

Synthetic assessment

The synthetic assessment summarises the expected impacts of the preferred option on competitiveness.

In general, the initiative is expected to have some small to moderate effects on private-sector IT businesses in two ways. First, the Frontex, with the support of eu-LISA, may procure the development of the new systems through a private contractor and, second, Member States may also procure private contractors to implement new systems or new system components.

No significant effects on any of the competitiveness dimensions provided in the Better Regulation Guidelines Toolbox ( 133 ) were identified. As the target stakeholders of the initiative largely comprise competent national authorities in the Member States, no major impacts are expected on e.g. companies’ production or compliance costs, any movements of goods in the Member States, investment flows, business shocks or businesses’ capacity to innovate and undertake research and development. The only expectable (very moderate) effects are in the area of outsourcing of tasks to private-sector contractors in the IT area (see above), which is not expected to impact competitiveness in the long-term. There are also no measurable effects that would particularly affect small- and medium-sized enterprises (‘SMEs’) across the Member States.

ANNEX 6: Data protection impact assessment for Option 1

Step 1: Identification of the need for a DPIA

Project purpose

Option 1 aims to enhance the digital management of RRR processes across EU Member States by introducing a harmonised national case management system based on the Frontex-developed RECAMAS Model, maintaining decentralised data storage while improving interoperability and coordination. In addition to national RECAMAS, EU-level tools such as iRCMS and RIAT will be integrated into national systems. Frontex will assume lead responsibility for the development and maintenance of the EU segments of iRCMS and RIAT, while third countries and international organisations will continue to manage the third-country segment of iRCMS. The architectural setup under this option does not include a central EU database or uniform interface. Instead, the ESP will be connected directly into the national RECAMAS, enabling Member States to query relevant EU Information Systems in line with access rights. IRMA and RECAP will be directly connected to the national RECAMAS-based systems, while iRCMS and RIAT will be integrated into national RECAMAS to support readmission and reintegration workflows, including direct communication with local reintegration partners. The Communication Portal will allow return authorities to share information that cannot be exchanged through EU Information Systems. This decentralised yet interconnected architecture aims to improve operational efficiency while providing some flexibility to Member States as regards return case management systems.

The processing activities under this option involve the collection, storage, and exchange of personal data of TCNs, including potentially sensitive categories such as biometric data, criminal records, and information related to health, vulnerability, and reintegration needs. These data are processed for the purposes of case management of RRR processes.

Need for a DPIA

In view of the risk factors set out above and taking into account the nature, scope, context, and purposes of the processing, it follows that the processing activities envisaged under the proposed digitalisation of RRR procedures in the EU require the performance of a DPIA, in accordance with Article 35 GDPR/Article 39 EUDPR and the guidelines of EDPB (‘the EDPB Guidelines’) ( 134 ).

The processing associated with this initiative presents the following risk factors that justify the need for a DPIA:

Processing on a large scale of special categories of data, or of personal data relating to criminal convictions and offences.

In order to determine whether the data is processed on a large scale, the following elements must be assessed: (i) the number of data subjects concerned, either as a specific number or as a proportion of the relevant population; (ii) the volume of data and/or the range of different data items being processed; (iii) the duration, or permanence, of the data processing activity; as well as (iv) the geographical extent of the processing activity ( 135 ).

In view of the above criteria, it can be concluded that this risk factor would be present in this case, taking into account that the processing (i) affects a significant number of TCNs across all EU Member States, (ii) involves the collection and exchange of special categories of data and data relating to criminal convictions and offenses (e.g. biometric data, criminal records, health data), (iii) over extended periods of time, and (iv) across a broad geographical scope. Also, the data is processed by multiple actors (national authorities, Frontex, eu-LISA) and exchanged across borders, further increasing the scale of the processing.

Conclusion

Based on all the above, it can be concluded that the processing activities envisaged under the proposed digital RRR system are subject to the obligation to carry out a DPIA.

Step 2: Description of the processing

Nature of the processing

The data processed will include all data necessary to complete the RRR processes and in particular:

·Information necessary to establish the identity of the TCN and, where applicable, the identity of his or her family members, relatives and any other family relations.

·Information related to the biometric data taken of the TCN in accordance with Regulation (EU) 2024/1358 ( 136 ).

·Information related to the nationality and any travel document(s) of the TCN.

·Information related to the TCN’s places of residence, routes travelled, languages spoken and contact details (electronic mail address(es) and phone number(s)).

·Information on any residence status or authorisations offering a right to stay, including residence documents or visas as well as any applications or extensions hereof, issued by a Member State or a third country.

·Information related to the return operation of the TCN.

·Information related to the return and reintegration of the TCN.

·The grounds for any return decision taken concerning the TCN.

·Information on the compliance of the TCN with the obligations under the return procedure.

·Information as to whether the TCN was detained or alternatives to detention were applied to the individual.

·Information related to the criminal records or related to the threat to public policy, public security or national security posed by the TCN.

·Information on vulnerability, health and medical needs of the TCN.

The purpose of the processing is to manage digitally RRR processes.

Data will be stored in national RECAMAS (and also at Frontex level as regards iRCMS and RIAT data), with each Member State maintaining control over its own data repositories. There will be no centralised EU database. Data retention periods will be defined at EU level, in accordance with the principles of data minimisation and storage limitation under the GDPR and the EUDPR.

Data sharing will occur in several ways:

·National RECAMAS will be connected to the ESP, which will allow authorities to query and retrieve the necessary information from relevant EU Information Systems such as SIS, Eurodac or EES.

·When the information cannot be retrieved through EU Information Systems, Member States will exchange information with each other through the Communication Portal, based on existing infrastructure (SIRENE, DublinNet, VIS Mail).

·iRCMS will be embedded into national RECAMAS and will allow the exchange of information with third countries.

·RIAT will be embedded into national RECAMAS and will allow the exchange of information with reintegration partners.

·Frontex digital tools such as IRMA, FAR and RECAP will be integrated into national RECAMAS to support exchange of information with Frontex and the communication with returnees.

Scope of the processing

The nature of the data includes both non-sensitive personal data - such as names, dates of birth, nationality, travel history, and contact details - and special categories of personal data as defined under Article 9 GDPR and Article 10 EUDPR, namely biometric data and health-related information. Data relating to criminal convictions and offences, as defined under Article 10 GDPR and Article 11 EUDPR, may be processed too.

The volume of data processed is expected to be substantial, as it will cover all TCNs subject to RRR procedures across the whole Union. Hundreds of thousands of return decisions are issued annually, and the systems will need to manage data for each case, including updates throughout the RRR process.

The processing of personal data will occur on a continuous basis, as the system is designed to support the long-term digital management of RRR procedures across the Union. This is not a one-off or time-limited project but rather a structural and operational framework intended to be embedded in the daily work of national migration authorities. Data will be collected, updated, and processed dynamically throughout the lifecycle of each individual case, from the initiation of return procedures to the completion of reintegration support (where applicable).

Personal data will be stored only for as long as necessary to fulfil the purposes for which it was collected, in accordance with Article 5(1)(e) GDPR and Article 4(1)(e) EUDPR. As underlined by the EDPS in its Opinion 9/2025 on the Commission proposal for the Return Regulation, there is a need to ensure consistent application of the EU data protection in the context of the return procedures as regard, among other things, the storage duration ( 137 ).

A duration of 10 years from the confirmation of return is considered to be necessary and sufficient for Member States to (i) complete all RRR processes, including reintegration, which may last several years after the effective return in the country of return and (ii) allow migration authorities to identify TCN who would return irregularly to the EU after having been returned. This duration should be longer where the return decision is accompanied by an entry ban. In this case, the retention period should be as long as the entry ban is in force or 10 years, whichever period is longer. When a return decision is withdrawn or annulled, there would be no reason to continue storing the data, which should therefore be deleted immediately.

Frontex does not act as a fully-fledged return authority, personal data processed for the purpose of performing tasks relating to return and readmission should be deleted no later than 30 days following the receipt of confirmation of return. Personal data processed for the purpose of reintegration should be stored for two years following the receipt of the confirmation of return. This longer retention period for data relating to reintegration is justified by the fact that the provision of reintegration assistance, under the EU Reintegration Programme run by Frontex and under several other national reintegration programmes, can extend to up to one year following the effective return. Following this one year, there is a need to continue keeping the data for an additional year for reporting purposes and ensuring that TCNs can be further referred to other reintegration programmes (outward referral) running in the longer term (e.g. implemented by third countries). Just as for Member States, when a return decision is deleted or withdrawn, Frontex should delete the corresponding data immediately. Personal data processed for the purpose of the development and operational management of iRCMS and RIAT (i.e. hosting the data) should be stored in compliance with the rules applicable to Member States.

Upon expiry of the retention period, personal data must be securely and automatically deleted, and appropriate technical and organisational measures must be in place to ensure compliance with these obligations.

The geographical scope of the processing is EU-wide. All EU Member States participating in the system will process and exchange data through their national case management systems.

The processing may extend to third countries in the context of readmission cooperation and reintegration, where data needs to be shared with competent authorities in countries of return and local reintegration partners. Such transfers will be subject to compliance with Chapter V GDPR/Chapter V EUDPR and the additional safeguards laid down by the Return Regulation.

Context of the processing

The processing occurs within national RECAMAS, which integrate EU-level modules (iRCMS and RIAT).

Data subjects are TCNs subject to RRR procedures. The data subjects include vulnerable groups, such as asylum seekers, minors, and individuals with medical or social vulnerabilities, which requires heightened safeguards and attention to data protection principles.

Each Member State will act as data controller for the data it records in its national RECAMAS, in iRCMS, and in RIAT as Member States will determine the purposes and means of processing personal data related to RRR. Each Member State will be considered as controller for the operational management of its national RECAMAS. 

Frontex will act as processor in relation to the data it records in national RECAMAS, iRCMS, and on cases from national reintegration assistance programmes managed in RIAT. In this case, the relationship between the parties must be governed by a clear and binding arrangement in line with Article 28 GDPR/Article 29 EUDPR. This arrangement must specify the scope, nature, and purpose of the processing, the types of personal data involved, and the categories of data subjects. It must also define the obligations and rights of the controller, including instructions for processing, the duration of processing, and the measures to ensure data security.

Member States and Frontex will be considered as joint controllers in relation to the processing of personal data recorded in RIAT for cases managed under an EU reintegration assistance programme. The responsibilities of each joint controller should be limited to the data it records in RIAT.

Frontex will act as processor for the operational management of iRCMS and RIAT.

Member States and Frontex may be considered as joint controllers in relation to the processing of personal data exchanged through the Communication Portal. The responsibilities of each joint controller will be limited to the data it processes in the Communication Portal.

eu-LISA will be considered as processor in relation to the operational management of the Communication Portal.

The systems and tools involved will be partially based on existing systems. There are no known major controversies or security flaws identified, although concerns have been raised in the past about the fragmentation of systems, inconsistent data quality, and the risk of errors due to manual processing.

The processing is not currently covered by any approved code of conduct or certification scheme specific to migration management or public sector IT systems.

Purposes of the processing

The purpose of the processing is to support the digital management of RRR cases, in compliance with the applicable legal framework. The general and specific objectives pursued are those referred to in Section 4 of the Impact Assessment.

Step 3: Consultation process

Given the nature and complexity of the processing activities, stakeholder consultation and expert input are essential components of the DPIA process. Member States, relevant IO and CSOs as well as relevant services of the Commission and relevant EU agencies have been consulted in the context of the Digitalisation Study.

Direct consultation with data subjects is not considered appropriate or feasible in this context, as the processing is carried out by public authorities in the exercise of official duties, and the individuals concerned will not have a direct relationship with the system’s design or governance. However, their rights and interests have been considered through the application of data protection principles and risk-based safeguards.

To support the assessment and design of the processing activities, the Commission has engaged EY and RAND Europe, who have provided technical, legal, and operational input throughout the development of the policy options. In addition, the EDPS has been consulted at a general level in the context of the Digitalisation Study.

Step 4: Assess necessity and proportionality

The conditions for the processing of personal data within the digitalisation of RRR procedures are regulated, for Member States, according to Article 6(1)(e) GDPR and, for the EU agencies and institutions, according to Article 6(1)(a) EUDPR, when the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The processing is carried out by national competent authorities and EU agencies in accordance with the future regulation on the digitalisation of case management in the area of RRR and the Return Regulation.

Where special categories of data are involved, such as biometric or health data, the processing is further justified under Article 9(2)(g) GDPR/Article 10(2)(g) EUDPR, which permits processing for reasons of substantial public interest. The processing of data relating to criminal convictions will be subject to Article 10 GDPR/Article 11 EUDPR and will be carried out under the control of official authority and as authorised by EU law providing for appropriate safeguards for the rights and freedoms of data subjects.

The processing is proportionate to its purpose, which is to address the problems identified in Section 2 of the Impact Assessment. In line with the principle of data minimisation, the processing does not go beyond what is necessary to achieve the objectives pursued. This is notably evidenced by the fact that Option 1 does not imply creating a new central EU database, which would mostly replicate data already stored in other EU Information Systems.

To prevent any function creep, the purposes of the processing will be clearly defined in a legislative framework. Access to personal data will be restricted to authorised personnel based on role and necessity, and any future changes in the scope or purpose of processing would require legal review, legislative changes and, where appropriate, a new DPIA.

Data minimisation and quality are ensured through the design of the systems, which limit the categories of data processed to those necessary for the RRR procedures and leverage EU Information Systems. Member States are responsible for ensuring data quality at the national level and reporting mechanisms at EU and national level will be established.

Although direct communication with data subjects may be limited due to the nature of the processing, individuals will be informed through privacy notices issued by national authorities and EU agencies, in compliance with the GDPR/EUDPR. Mechanisms will be in place to support the exercise of data subject rights, including access, rectification, restriction, and the right to lodge a complaint with a supervisory authority. These rights will be facilitated through national data protection supervisory authorities and the EDPS, depending on the level at which the processing occurs.

Processors will be bound by data processing agreements or the respective regulation in accordance with Article 28 GDPR and Article 29 EUDPR. These agreements will define the scope, purpose, and duration of the processing, as well as the technical and organisational measures required to ensure compliance. Processors will act only on documented instructions from the controller and will be subject to audit and oversight mechanisms to ensure accountability.

Where personal data will be transferred to third countries, for example, in the context of readmission cooperation, the conditions of such transfers will be governed by Chapter V GDPR and Chapter V EUDPR and further applicable safeguards stemming from the Return Regulation as eventually adopted.

Step 5: Identification and assessment of risks

Step 6: Identify measures to reduce risk

Potential of artificial intelligence for digital migration management

ANNEX 7: Detailed impacts of the options

‘Baseline scenario’

Assessment of effects

Effectiveness

Under the baseline scenario, the problems identified in Section 2 will remain unresolved, negatively impacting the effectiveness of RRR processes. The general and specific objectives will not be achieved.

The figure below illustrates that in all areas critical to achieving the objectives, Member States have indicated a pressing need to address the problems – otherwise facing the risk to continue encountering these issues in the future ( 138 ). For example, 21 Member States stated that the problem of data sharing would remain if no change was made (see Table 152 of the Digitalisation Study for a more detailed breakdown of Member States’ views on this regard).

Figure 11 - Member States' assessment of the importance of the current problems that are likely to arise in the future if no action is taken (n=21)

Source: Survey conducted as part of the Digitalisation Study

This finding is supported by the interviews conducted as part of the Digitalisation Study, which revealed that the RRR processes are not handled as effectively as they could be. One of the most frequent points mentioned was the lack of interoperability between national and EU systems, complicating effective case management.

The availability and quality of information and statistics are not expected to improve, as the Member States will continue to grapple with problems related to data sharing and non-standardised information. This lack of consistency and reliability in data directly impacts the usability of information in RRR processes, potentially leading to misinformed decisions and inefficient case management.

Moreover, if the current high level of manual intervention remains unchanged, it may lead to continued lengthier procedures, risk of errors as well as limited automation. The reliance on human input for data entry and processing obstructs the implementation of automated systems that could enhance effectiveness and streamline RRR processes.

Figure 12 - Most crucial operational challenges stemming from the existing systems (n=22)

Source: Survey conducted as part of the Digitalisation Study

In terms of speeding up procedures while simultaneously reducing workloads, the fragmentation of systems and the absence of interoperability are expected to perpetuate delays and continue to create undue workloads for authorities. This fragmentation not only complicates communication among stakeholders but also prevents the effective sharing of critical information, further straining competent authorities and hindering efforts to streamline RRR processes.

Additionally, the continued existence of silos, stemming from custom-built national systems and inconsistent data sharing practices, is expected to undermine broader European governance in RRR. This prevents effective coordination and collaboration among the various stakeholders involved in digital migration management, leading to a disjointed approach that fails to address the complexities of the migration landscape.

Under the baseline scenario, it is expected that the situation will remain sub-optimal for Member States with regard to managing RRR processes migration effectively on their own. The current system is characterised by significant divergence in effectiveness across Member States. While some interviewees reported that their national systems perform sufficiently well, others pointed to major inefficiencies. These disparities are also reflected in the survey results, revealing a fragmented landscape with varying levels of capability. The lack of consistency in systems, standards, processes, and communication already hampers national efforts and undermines collective EU action. Without a coordinated approach, this fragmentation is expected to persist, preventing meaningful improvements and weakening the EU’s overall migration strategy.

Efficiency and administrative burden

In terms of efficiency, the baseline scenario demonstrates a low level of costs but is overall not expected to be efficient as it fails to achieve the intended objectives and benefits.

The established infrastructures will continue to be operational and existing systems are fully integrated into the daily operations of various authorities, meaning that there are minimal development and implementation costs associated with their continued use. Since the systems are already in place, Member States can avoid the significant financial outlay that would be required for new system development or extensive upgrades, unless they decide to do so on their own initiative. This would allow to allocate resources to other pressing needs within the digital migration management framework.

Moreover, the familiarity of officers with the current systems is a crucial benefit. With personnel already trained and experienced in using these systems, there is a reduced need for additional training sessions, except for new hires, which can be both time-consuming and costly. This familiarity allows officers to navigate the systems efficiently in terms of cost. However, under the baseline scenario, other aspects of the process - such as speed and accuracy - would continue to be inconsistent or suboptimal.

As the figure below shows, costs such as management costs, compliance costs and documentation costs are not considered particularly high by the Member States but rather moderate. For example, 60% (N=12) of the Member States responding to the survey rated the current compliance costs as low whereas 25% (N=5) classified the costs as moderate and only 15% (N=3) as high. The assessment of other costs, such as costs for hiring staff or storing data, is similar to this example.

Figure 13 - Member States' ratings of the magnitude of current costs (n=20)

Source: Survey conducted as part of the Digitalisation Study

However, despite these factors, the overall efficiency of digital migration management does not improve under the baseline scenario, primarily due to the continued use of fragmented, custom-built systems that lack sufficient automation, interoperability and ways to cooperate and coordinate with other Member States. 10 Member States highlighted ongoing fragmentation, limited data exchange, and a lack of innovation as critical drawbacks. Five of these specifically pointed to the continued lack of harmonisation and integration as a major concern, particularly regarding cooperation and data sharing between the Member States ( 139 ).

Thus, despite the cost advantages in the short term, the cumulative effect of fragmented systems and manual workloads diverts resources away from more strategic, long-term investments. This could, potentially, contribute to staff fatigue and turnover, as experienced personnel face high workloads and limited system support. Replacing them with less experienced staff further strains efficiency, as new personnel require time and training to adapt to existing systems. These dynamics perpetuate a cycle of inefficiency that affects the overall capacity and responsiveness of RRR.

Coherence

The baseline scenario is considered to be neither internally nor externally coherent due to several interrelated factors, notably the (i) lack of unified approaches in digital migration management and (ii) clear responsibilities in managing RRR processes.

As concerns the internal coherence of the policy option: as outlined in detail in Section 2 , the digital management of RRR is fragmented and operates in silos, rather than as a cohesive and integrated system. This is exemplified by the fact that 19 Member States indicated in the Digitalisation Study’s survey that they have developed customised national systems ( 140 ). The fragmentation leads to diverse governance structures, with various stakeholders responsible for IT system development and maintenance, resulting in inconsistent practices across the Member States. Moreover, the lack of standardised protocols for integrating national systems with EU-level interoperability components further deepens the incoherence. Without a unified strategy, the Member States are likely to pursue divergent paths in their digital migration management efforts, creating a disjointed approach overall. Interviews also revealed significant disparities in the levels of digitalisation and technological capabilities among the Member States, which further complicate RRR process management. These variations hinder the development of a cohesive management for RRR cases and processes as well as impede the effective sharing of critical data, especially for return procedures. Lastly, the responsibilities of stakeholders involved in the process are not always clear, making it hard for practitioners to identify the right points of contact.

As concerns the external coherence of the policy option: this option lacks full coherence with the broader EU framework, primarily due to the limitations imposed by the current implementation of national systems, although these systems could be connected in a near future to the ESP. Under the baseline scenario, the intended improvements in cooperation and data exchange outlined in the Pact on Migration and Asylum and in the Return Regulation may prove more difficult to achieve. The lack of a unified approach to data sharing means that the collaborative efforts envisioned in these new policies cannot be realised, resulting in missed opportunities for enhanced coordination among the Member States.

Assessment of impacts

Economic

The baseline scenario is expected to have no impact on the EU economy. This is primarily due to the fact that the impacts in this regard are expected to be limited in scope.

The impact on public budgets will be minimal in terms of increased costs, as the existing infrastructure in Member States is already in place and operational. However, public budgets will continue to absorb the costs of inefficient processes, such as manual workflows and prolonged case handling, which do not deliver proportional benefits. The maintenance costs are estimated at EUR 3.32 million per Member State per year (EUR 24 million in total) ( 141 ). 

In terms of other economic aspects, such as the effects on SMEs, competitiveness, or property rights, no notable changes are anticipated. The baseline scenario does not offer any substantial stimulus for innovation or growth, as it does not involve new technological developments or investments in migration-related IT systems.

Societal

The societal impact of the baseline scenario is assessed as negative.

The continuing insufficient digitalisation does not lead to sufficient improvement in the coordination of RRR processes and is thus expected to further fuel public discontent, deepen social divides, and erode trust in institutions, ultimately weakening the EU’s ability to tackle a politically sensitive issue.

Moreover, the baseline scenario is likely to continue reinforcing the public perception that returns are not managed sufficiently effectively or fairly, strengthening the narrative of institutional failure in migration governance. The lack of integration between systems, and inconsistent practices may undermine the EU’s credibility and control in an area of significant public concern. This fragmentation, compounded by insufficient monitoring and accountability, will likely persist.

Furthermore, the inadequate management of returns and the continued presence of high numbers of irregular staying TCNs already places a significant strain on social systems, diverting resources and limiting the overall capacity to address other pressing societal needs, a trend expected to persist.

However, it should be noted that while TCNs may contribute to the economy, particularly in sectors such as agriculture, construction, and caregiving, these same sectors – often reliant on low-skilled labour – are also among the most common employers of irregular staying TCNs. Small to medium-sized enterprises, in particular, are considered high-risk for illegal employment ( 142 ). Under the baseline scenario, this continued reliance on irregular labour risks sustaining exploitative practices and undermining fair labour standards, representing a negative societal impact of irregular migration that would remain unaddressed.

Environmental

The baseline scenario is expected to have a negligible negative impact on the environment.

The continued reliance on existing IT systems with varying levels of modernity and manual processes may lead to higher resource consumption and waste generation, contributing to a larger environmental footprint. The persistence of such inefficient methods reflects missed opportunities to adopt more sustainable approaches in the management of RRR processes.

The absence of new infrastructure or technology deployment in this scenario will help to mitigate environmental impacts by avoiding additional consumption of raw materials, such as plastics.

Security

The security impact of the baseline scenario is expected to be negative, both in terms of the internal security of the systems themselves and their ability to contribute to greater security within the EU.

Regarding the system level, the interviews revealed that security is currently undermined by the lack of interoperability, reliance on manual processes, and fragmented data handling. The absence of integrated systems leads to manual updates across systems, significantly increasing the risk of errors and compromising the integrity of sensitive information. These vulnerabilities are compounded by limited safeguards for secure communication and data exchange, an issue noted by 14 of the Member States. Concerns about data privacy were also raised by 13 Member States, indicating that the current framework does not adequately meet security and privacy standards ( 143 ).

The disjointed systems may create conditions that could be exploited by individuals posing potential security threats. From a broader EU security perspective, the baseline scenario will continue to hinder authorities' ability to conduct comprehensive risk assessments. Interviewees highlighted that the inability to access key databases – such as criminal records, tax, or social security information - already hampers the ability to fully evaluate the potential risks posed by individuals.

While the introduction of systems, such as the EES, and ETIAS in the future, as well as upgrades of existing systems, such as Eurodac and VIS, may positively impact security, the structural and operational weaknesses within the baseline scenario will still persist, limiting their effectiveness. While systems like SIS do enable a degree of monitoring, the absence of more comprehensive sharing mechanisms will continue to leave gaps in the enforcement of return decisions. Interviews carried out as part of the Digitalisation Study confirmed that challenges related to data availability and cross-border information exchange will remain unresolved.

The persistent fragmentation and lack of interoperability among EU digital migration management systems not only impede operational efficiency but also elevate the risk of data misuse, breaches, and cybersecurity failures.

Fundamental rights

The baseline scenario is assessed to be in line with fundamental rights at present.

However, looking ahead, concerns may emerge regarding the protection of personal data, particularly for TCNs. These concerns are not based on confirmed violations but rather stem from assumptions linked to systemic limitations, such as the fragmented nature of the policy option.

As can be seen in the figure below, there is some disagreement among the Member States about compliance with fundamental rights with regard to the use of digital tools in the baseline scenario. Eight Member States responding to the Digitalisation Study’s survey stated that they have some concerns regarding compliance with fundamental rights, while seven disagreed. The remaining eight Member States surveyed were indifferent to the statement.

Figure 14 - Member States' indication of whether there are concerns regarding the protection of fundamental rights when using digital tools (n=23)

Source: Survey conducted as part of the Digitalisation Study

Interview feedback reinforces this picture, pointing to risks associated with the gap between the technical implementation of digital tools and the legal provisions intended to safeguard data protection. In particular, the lack of a centralised or harmonised approach makes it difficult to monitor compliance across Member States, increasing the risk that potential issues go undetected.

In this context, while there is no evidence of systemic breaches of fundamental rights today, the baseline scenario may not offer sufficient guarantees to ensure that these rights can be consistently upheld in the future. The ability to monitor, manage, and ensure rights protections across Member States may become increasingly difficult if current conditions remain unchanged.

Feasibility

Overall, the baseline scenario is considered feasible in the short term but not sustainable in the long-term.

As shown in the figure below, the survey results show that Member States consider the baseline scenario as generally (highly) feasible in all respects, which is particularly due to the fact that the systems are already up and running. In addition, and as confirmed by the interviews, most Member States feel comfortable with their existing national systems and specifications as well as with the established legal basis in place.

Figure 15 - Member States' ratings of the feasibility of Option 0 (n=22)

Source: Survey conducted as part of the Digitalisation Study

Although the baseline scenario is overall currently considered feasible, the interviews showed that stakeholders do not consider this policy option to be durable and sustainable in the long term. As already outlined in the problem assessment (Section 2 ), there are too many problems and drivers present that will continue to limit the effectiveness and efficiency of case management of RRR. The prevailing views are that the baseline scenario lacks the necessary changes to effectively manage RRR processes in the long term.

Option 1 ‘Partially decentralised option without central EU database’

Assessment of effects

Effectiveness

Option 1 is expected to achieve the specific and general objectives to a high extent in the short-term.

By leveraging existing EU Information Systems (e.g. by connecting national RECAMAS to the ESP) and introducing a new Communication Portal, cumbersome and fragmented information exchanges between authorities are expected to be reduced. This structural improvement will likely enhance both the quality and availability of information by ensuring more consistent, timely, and accessible data sharing. As a result, RRR processes can be carried out more efficiently, easing the workload on authorities and enabling quicker responses and decisions which is critical to manage urgent RRR cases.

The degree of manual intervention is expected to decrease significantly, as standardised EU systems on readmission (iRCMS) and reintegration (RIAT) as well as the widespread use of RECAMAS-based solutions will reduce the need for manual data reformatting, speeding up procedures and minimising human error.

The establishment of a Communication Portal is moreover expected to foster more direct coordination between authorities, which is expected to diminish the current tendency to work in silos.

In addition, under this policy option, the system established for digital migration management would largely build upon already existing system and models. Whereas the national systems would build upon the already well-established RECAMAS Model, or its reference implementation developed by Frontex, the communication infrastructure will build upon existing infrastructure (e.g. SIRENE, DublinNet, VIS Mail).

Reliance on existing infrastructure preserves operational continuity and is expected to enhance stakeholder acceptance, as the targeted interviews conducted in the context of the Digitalisation Study have indicated. Stakeholders expressed a wish for continuing to use the already well-established systems, underlining that an approach which could be considered too disruptive would likely reduce stakeholder acceptance. This is also confirmed in the survey conducted in the context of the Digitalisation Study, with Member States indicating that interoperability with existing systems and a modular as well as flexible infrastructure are more important to them, whereas the adoption of a central infrastructure is less favoured.

Figure 16 - Member States’ perception of the most crucial design features for an integrated case management system (see Table 157 of the Digitalisation Study) n=24

Source: Survey conducted as part of the Digitalisation Study

The benefits associated with Option 1 should be understood in the light of the fact that a fast and effective short-term solution is needed at the moment, in order to quickly mitigate the effects stemming from the problems outlined in Section 2 . Option 1 can be implemented comparatively fast, given that there would be no need to develop an additional EU central database. The comparatively swift implementation timeline thus enables an early delivery of benefits and transition towards the objectives, reducing the time that is continuously spent in status quo.

The reliance on ‘only’ a communication tool for the exchange of ad-hoc information (i.e. information that cannot be exchanged through existing EU information systems) and the absence of a shared database used by all Member States may create risks for incorrect data being transmitted or miscommunication occurring, in case working instructions concerning the Communication Portal are understood and applied differently depending on the users. Without clearly defined instructions and agreed-upon standards for use, Member States may adopt differing practices, which could lead to inconsistencies in data exchange and potential delays in processing.

In addition, there are limitations and caveats to the effectiveness of Option 1:

·The effectiveness and efficiency of this policy option will partially depend on the extent to which in the future (1) the completeness of the information stored in EU Information Systems will improve and (2) the information contained in the return decisions stored already in the SIS are used in practice to manage returns.

·The effectiveness and efficiency of this policy option will depend on the extent to which Frontex will be capable to deliver its tasks in the required quality and time. It will be essential that Frontex closely work with eu-LISA, Member States and the Commission to deliver. For this purpose, specific governance’s arrangements should be established (e.g. similar to what is in place with eu-LISA to develop EU Information Systems through advisory groups and project management boards or through a different approach).

·The exchange of information between Member States will be limited to case-by-case needs. While SIS return alerts and the bilateral or multilateral information exchange between SIRENE Bureaux enable Member States to monitor secondary movements or identify persons who should be subject to return processes, it only facilitates data exchange on a case-by-case basis and only the sender and receiver are aware of the information shared. Similarly, the ESP will not function as a tool for information exchange under Option 1. The ESP will merely provide access to the data from all existing and future EU Information Systems, such as SIS, VIS, Eurodac and EES in line with access rights, as in the baseline scenario. Consequently, Member States will remain unaware of what other Member States are processing regarding a specific TCN until a return alert is shared via SIS or the data is uploaded in another EU Information system e.g. Eurodac.

Efficiency and administrative burden

The efficiency of Option 1 is expected to be moderate. However, its effects are expected to materialise rather short-term. Despite relatively high costs for Member States, the option is still rated the most efficient given the very limited ‘sunk costs’ of Member States. The automation of multiple processes will significantly reduce the administrative burden for migration authorities. In the short-term, the financial investment required is expected to be relatively moderate, focusing on four key areas: (i) adapting national RECAMAS that are not yet aligned with the RECAMAS Model, establishing iRCMS and RIAT and integrating those in national RECAMAS, (iii) setting up the Communication Portal, (iv) connecting national RECAMAS to the ESP for performing queries as well as (v) to SIS for the creation of return alerts. According to Article 66(2) of the Interoperability Regulation, costs that incur due to integrating the interoperability components, such as the ESP, with existing national infrastructures will be borne by the general budget of the Union. Once these adaptations are made in a relatively short term, the Option 1 is expected to become fully operational. This can be expected to significantly limit the costs that Member States would otherwise have to spend if the time horizon until the operation of the system would be long-term. Therefore, Member States are not expected to incur a significant amount of ‘sunk costs’ under Option 1.

The introduction of the Communication Portal will facilitate more efficient and timely exchanges of information between Member States, ultimately improving the identification of individuals and the completion of RRR processes. Option 1 is expected to promote the harmonisation of national RECAMAS, in part thanks to the additional EU-developed components on readmission (iRCMS) and reintegration (RIAT), which will be integrated into national RECAMAS.

In the long term, Option 1 is not expected to maintain the same level of cost-efficiency as is expected in the short-term. While it is comparatively straightforward to implement and incurs low initial costs, its reliance on the Communication Portal for the ad-hoc exchange of information may introduce potential inefficiencies. If no standardised data format for communication is agreed upon, there is an increased risk of transmitting incorrect or incomplete data, which could disrupt RRR processes and require additional time and resources to resolve inconsistencies. However, should standardised formats for communication be established, these risks would be largely minimised, leading to a more efficient and streamlined process overall.

Based on the methodology, as well as the overarching and policy option-specific assumptions provided in section 5.1 in Annex 9, costs for the Member States, Frontex, eu-LISA and the Commission are expected to range between EUR 582.39 and 753.17 million. Sunk costs are negligible under Option 1, as Member States will build upon existing systems at national level and the short-term operational nature of this option. This includes hardware and software investments, development, as well as maintenance and support across six years. A more detailed breakdown, as well as the methodology and underlying assumptions, are provided in Annex 9.

Coherence

Option 1 is expected to improve the internal coherence of EU digital migration management. Option 1 is considered to be externally coherent.

In terms of internal coherence, this option is expected to facilitate a minimum level of harmonisation in the areas of RRR by leveraging the RECAMAS Model and Frontex RECAMAS. The integration of iRCMS and RIAT into national RECAMAS is likely to reduce the current fragmentation, promoting a more unified approach across Member States. Additionally, leveraging existing data from systems such as SIS and Eurodac enhances coherence by minimising the duplication of structures and building upon pre-existing systems. This policy option further clarifies institutional responsibilities, with Frontex taking the leading role in the development and maintenance of iRCMS and RIAT and supporting Member States to adjust their national RECAMAS. The use of the existing infrastructure (e.g. SIRENE, DublinNet, VIS Mail) for the Communication Portal will help to avoid duplication of structures and contributes to coherence by building upon established frameworks, supporting the standardisation of procedures and reducing fragmentation. eu-LISA will be responsible for the development of the Communication Portal, which is coherent with its current responsibilities on existing communication infrastructure (e.g. SIRENE, DublinNet, VIS Mail).

Regarding external coherence, Option 1 is expected to make use of the interoperability infrastructure by connecting national RECAMAS, iRCMS and RIAT to the ESP.

Option 1, as all policy options, would need to be coherent with and accommodate the procedural novelties introduced by the Return Regulation. Therefore, this constitutes a horizontal requirement and is not a differentiating element between options. Option 1 is expected to enhance coherence with the Return Regulation, as it facilitates adequate information sharing between the Member States and the automation of the creation of statistical data, thanks to the connection of the CRRS to national RECAMAS, iRCMS and RIAT.

Assessment of impacts

Economic

Under Option 1, potential positive and negative economic impacts are expected to balance each other out.

That being said, Option 1 provides Member States with flexibility to either continue developing their existing national systems in line with the RECAMAS model developed by Frontex or to adopt the off-the-shelf RECAMAS-based IT solution developed by Frontex. This dual approach allows Member States to build on prior investments while ensuring convergence towards a common framework. At the same time, it offers a cost-efficient alternative for those Member States with less mature case management systems, which would benefit from the off-the-shelf RECAMAS-based IT solution, reducing spending only to the customisation of the model.

Over time, the one-off and recurrent costs may be offset by efficiency gains thanks to the improved digital migration management.  

Since Member States still need to invest in IT infrastructure and development, this policy option might result in a minor economic stimulus for Member States’ local IT industry and market. However, it is expected that this would affect larger established IT companies rather than SMEs and start-ups. Thus, there is next to no impact on competition expected.

No impacts are expected on issues such as technological developments, consumers and households, innovation, or education and training systems.

Societal

Option 1 is expected to have minor positive societal impacts compared to the baseline scenario.

The improvement of digital migration management is expected to positively contribute to supporting the social inclusion of TCNs and their smooth integration into the regular labour market, by accelerating procedures for those who have no right to stay.

While the impact on employers in sectors relying on TCNs may be marginal, it will offer more certainty regarding the recruitment of legal workers.

Overall, this option is also expected to contribute to strengthening public trust in the EU’s and Member States’ capacity to manage migration effectively.

Environmental

Option 1 is expected to have a negligible negative impact on the environment compared to the baseline scenario.

Although the reuse of existing systems and the Communication Portal under this option contribute to resource efficiency and reduce the need for new infrastructure, the restructuring process itself will require additional energy and resources, particularly in Member States undertaking significant system upgrades.

As outlined in Table 2 , only 12 Member States have national systems based on RECAMAS in place, meaning that the majority of Member States would need to adjust their systems to reach alignment with the RECAMAS Model.

Overall, as the EU intervention is not significantly disruptive, the negative environmental impacts are expected to be negligible.

Security

Option 1 is expected to significantly contribute to increase the security of citizens, businesses, and public administration in the EU, most importantly because certain existing problems in digital migration management with regard to RRR could be addressed in the medium to short-term.

The close relationship between system effectiveness and security outcomes means that improvements in identification, data exchange, and coordination directly contribute to greater public safety.

One of the key advantages of Option 1 lies in its rapid adaptability as it can be implemented relatively quickly by Member States, allowing relevant authorities to better identify and address high-risk individuals shortly after the implementation.

Cross-border cooperation is supported through the Communication Portal, enabling more seamless and protected data exchange between Member States. While this represents a step forward in strengthening cybersecurity and reducing fragmentation, the continued reliance on a decentralised structure presents limitations. In particular, the absence of standardised data formats or automated validation checks can lead to inconsistencies and errors in information exchange. Moreover, the effectiveness of the system depends heavily on Member States using the Communication Portal as well as existing digital migration management systems consistently and correctly.

Fundamental rights

Option 1 is expected to adhere with fundamental rights and thus not expected to have any further positive nor negative impact compared to the baseline scenario. As Member States will continue to be responsible for the national systems they operate (even though they will now be based on the RECAMAS Model, either indirectly or directly by customising the newly developed Frontex RECAMAS), the fundamental rights situation is expected to stay the same as in the baseline scenario (see Section 5.1 of Part 2 of the Digitalisation Study).

As this policy option introduces a new approach to managing RRR processes, certain fundamental rights-related challenges may emerge. These could include risks to data protection, inconsistencies in the implementation of safeguards, or varying levels of system readiness across Member States. While the exact implications remain difficult to predict at this stage, the shift from the baseline introduces a degree of uncertainty, and some risk – albeit expected to be limited – cannot be ruled out.

Option 1 could offer tangible improvements in terms of transparency and efficiency. The secure exchange of information may not only speed up case handling but also make it easier for authorities to follow the progress of individual RRR cases. For TCNs, this could translate into clearer procedures and potentially greater access to the information held about them – a step toward strengthening data subject rights and building trust in the system. By embedding more structured and protected channels for communication, this option may offer a more rights-compliant and user-aware framework for managing sensitive migration-related data ( 144 ).

Feasibility

Option 1 is expected to be highly feasible.

From a perspective of political feasibility, stakeholder consultations have shown that most Member States prefer policy options that are the less disruptive when it comes to improving RRR. When asking stakeholders which policy options they prefer, a majority of stakeholders (81%, N=17) indicated that they prefer decentralised and/or hybrid solutions, as is indicated in the figure below (see also Table 158 of the Digitalisation Study) ( 145 ): 

Figure 17 - Member States' preference with regard to a new RRR system's architecture (n=20)

Source: Survey conducted as part of the Digitalisation Study

The results clearly indicate that most Member States prefer a solution that retains at least a certain degree of national autonomy. Consequently, and given that Option 1 is relatively less disruptive, it is reasonable to anticipate broad acceptance among stakeholders, enhancing its political feasibility. In addition, although this policy option may not be the most cost-effective in comparison, it is still more affordable than Option 3, which could further bolster its political feasibility. Moreover, it can be deduced from the stakeholder consultations that the preference for less fragmentation while maintaining flexibility is appealing which is what Option 1 stands for. Additionally, Option 1 allows for Member States to choose their preferred approach (i.e. either to adopt and customise the Frontex RECAMAS or to keep their existing RECAMAS while aligning it on the RECAMAS Model). This flexibility is likely to garner some support, contributing to the overall political feasibility of this option.

In terms of technical feasibility, Option 1 is expected to entail only minor to moderate technical adaptions to be undertaken by the Member States to their national systems. Tasks can be expected for the re-modelling of the national RECAMAS (either by adopting and customising the Frontex RECAMAS, or parts of it, and/or by aligning the national RECAMAS on the RECAMAS Model), integrating iRCMS and RIAT in national RECAMAS, connecting national RECAMAS to the ESP and to SIS, and ensuring that Member States are connected to the Communication Portal. As Frontex will provide support to Member States, the technical feasibility is expected to be high. The development of Frontex RECAMAS by Frontex as well as the integration of iRCMS and RIAT into the national RECAMAS will require substantial resources and expertise, which raises the technical feasibility to a moderate level, even if eu-LISA will also support Frontex in this task.

Lastly, in terms of organisational and operational feasibility, Option 1 is expected to be highly feasible, given the relatively low complexity of the policy option and the opportunity for stakeholders to work with well-known systems.

Option 2: ‘Partially decentralised option with central EU database’

Assessment of effects

Effectiveness

Option 2 is expected to achieve the specific and general objectives to a moderate extent, albeit only in the medium to long-term.

Evidence gathered from interviews with national authorities in the context of the Digitalisation Study indicates a general optimism about the option's ability to streamline processes by leveraging existing national systems while integrating them into EU-wide frameworks. As can be seen in the figure below, this finding is supported by the survey results, according to which 17 Member States consider Option 2 to perform better in regard to interoperability than the baseline scenario ( 146 ).

Figure 18 - Member States' ratings of the partially decentralised option’s performance compared to the baseline scenario (n=21)

Source: Survey conducted as part of the Digitalisation Study

Interviewees further highlighted that Option 2 is likely to enhance cooperation among stakeholders involved in RRR processes, thereby improving the monitoring of individuals throughout the whole process. This is particularly due to the enhanced data sharing of this option, with 14 Member States considering it to be significantly better than the baseline scenario.

The more centralised approach is generally expected to lead to improved availability and quality of information, particularly in alignment with the increased data sharing anticipated under the Return Regulation. By providing all Member States with equal access to necessary data, the central database aims to mitigate the current issue of data fragmentation, which has been a significant barrier to effective digital migration management.

However, as a major restriction, stakeholders noted during the interviews that the effectiveness of the tools within the architecture of this policy option is contingent upon the quality and availability of the data inputted by the Member States. Consistent updates to the national systems and accurate provision of information are essential to maximise the utility of this option. In this respect, the survey results show that the Member States do not consider the accuracy and reliability of the data to become better on the whole. While 10 Member States consider data accuracy and reliability to be better under Option 2, two consider it hardly better and eight see it as equally good as in the baseline scenario (see Figure above ).

If Option 2 is implemented as intended, the improved access to necessary data, opportunities to implement automated tools and the opportunities for information exchange are likely to speed up the processing of cases, as the need for manual processes is reduced. 12 Member States have backed this finding, by pointing out that Option 2 is ‘much more’ or ‘more’ favourable than the baseline scenario when it comes to automation. With a centralised database, the need for making bilateral requests for critical information is expected to be diminished, allowing authorities to more swiftly access all necessary data needed for their operations.

Lastly, the adoption of the central database is expected to reduce siloed working, as it would enable streamlined, role-based access to relevant information held by other national authorities, ensuring that only those with a legitimate operational need can retrieve the data.

However, the overall effectiveness of Option 2 is expected to be moderate, primarily because it is not likely to be operational in the short term. The complex technical implementation required to establish the central database may take several years, during which time existing problems in digital migration management will remain unresolved. This delay could hinder the timely achievement of both specific and general objectives, pushing them further into the future.

Efficiency and administrative burden

The efficiency of Option 2 is expected to be moderate. Its effects are expected to materialise only in the medium- to long-term. The costs are expected to be the highest among all policy options with ‘sunk costs’ of Member States also expected to be higher than in Option 1 (but lower than in Option 3).

Several interviewed Member States emphasised that the shared EU and national systems option would be more efficient than the baseline scenario. This is primarily due to more automated processes leading to faster procedures, which are expected to lead to time savings and a reduction in administrative workload. In this context, the newly established central database is a key component, as it would enhance data-sharing capabilities and significantly expand the potential for generating relevant statistics.

Moreover, Option 2 can be regarded as efficient as it builds upon existing systems and structures (national RECAMAS, iRCMS, RIAT). By retaining and upgrading current systems, rather than replacing them entirely, the option leverages existing infrastructure to improve overall efficiency. However, the benefits noted are rather expected in the long-term, once it is implemented. In addition, the above-mentioned efficiency is accompanied by the creation of a new central database, the necessity of which may be questioned as most data stored in this new database will already be stored in other EU Information Systems (e.g. SIS, Eurodac).

In the short-term, efficiency of this option is expected to be limited. As illustrated in the figure below, Member States anticipate substantial costs across all dimensions. For instance, 14 Member States classify the integration and interoperability costs as (very) high, while the remaining six expect these costs to be moderate.

Figure 19 - Member States' ratings of the magnitude of costs (n=20)

Source: Survey conducted as part of the Digitalisation Study

Stakeholder consultations further indicate that Option 2 would involve significant development and implementation expenditures, alongside sunk costs. Implementation is expected to be particularly resource-intensive, requiring adaptations to national systems as well as the creation of a new central database. This dual effort will result in considerable additional workload for both EU and national authorities. In particular, eu-LISA would face a substantial and heavy workload, as it would be responsible for developing the central database from the start.

In addition, the full implementation of this policy option is projected to take several years with a gradual go-live, which would further delay the full realisation of its efficiency. Furthermore, the expected gains do not appear to be proportionate to the anticipated costs. Much of the data intended to be shared via the new central database is already accessible through existing systems such as SIS, EES and VIS as well as will be available through upgraded and future systems such as Eurodac.

Based on the methodology, as well as the overarching and policy option-specific assumptions provided in Section 5.2 in Annex 9, costs for the Member States, Frontex, eu-LISA and the Commission are expected to range between EUR 700.30and 891.28million. This includes hardware and software investments, development, as well as maintenance and support across six years. Sunk costs are negligible under Option 2, as Member States will build upon existing systems at national level and the short-term operational nature of this option 

A more detailed breakdown, as well as the methodology and underlying assumptions are provided in Annex 9.

Coherence

Option 2 is expected to improve the internal coherence of EU digital migration management to a moderate extent. Option 2 is also considered to be externally coherent.

Internal coherence is expected to be enhanced through the creation of a central database, which will facilitate data sharing among the Member States by systematising it and ensure that Member States have access to the same data. The implementation of national RECAMAS as well as integration of iRCMS and RIAT, supported by eu-LISA and Frontex, is expected to promote a more harmonised approach to managing return cases across Member States as it not only harmonises and standardises RRR management practices but also promotes enhanced cooperation among stakeholders. The clear delineation of responsibilities among stakeholders, including the Member States, eu-LISA, and Frontex further bolsters the coherence of this approach and mitigates the risk of duplicative efforts.

However, the coherence of Option 2 is highly dependent on the Member States’ implementation of the system. Variations in national implementation, as well as differences in data sharing and operational working practices, could negatively impact coherence.

In terms of external coherence, Option 2 is set to fully leverage the EU’s interoperability framework. By connecting the central database to the CIR, sBMS, MID and ESP, the option will enable quick identification of duplicate entries. In addition, this policy option would expand the scope of data currently exchanged via EU Information Systems.

An adaptation of the Interoperability Regulation and of all founding Regulations of existing EU Information Systems is necessary in order to make use of all interoperability components and to allow the direct exchange of data between the new central database and EU Information Systems. As eu-LISA and Frontex will take on new responsibilities under Option 2, an amendment to the EBCG Regulation and to the eu-LISA Regulation will be required.

Option 2, as all policy options, would need to be coherent with and accommodate the procedural novelties introduced by Return Regulation. Therefore, this constitutes a horizontal requirement and is not a differentiating element between options.  

The policy option is coherent with data-sharing provisions and statistical reporting under the Return Regulation and the overall objectives of the Pact on Migration and Asylum. 

Assessment of impacts

Economic

Under Option 2, potential positive and negative economic impacts are also expected to balance each other out. The line of argumentation developed for Option 1 also applies to Option 2.

However, there are some notable differences: first and foremost, Option 2 does not only strain Member States’ budgets but also the EU’s budget to a slightly greater extent than Option 1, due to the creation of a central database.

Moreover, Option 2 could in addition to the economic stimulus in the Member States also provide a minor stimulus to larger IT companies that are serving EU bodies such as eu-LISA.

Societal

Option 2 is expected to have moderate positive societal impacts compared to the baseline scenario.

The same types of societal impacts can be expected to materialise as under Option 1. However, the magnitude of the impacts might be somewhat more pronounced through the establishment of the EU central database and the improvements of the effectiveness and efficiency of digital management of RRR over time.

Environmental

Option 2 is expected to have a limited negative environmental impact compared to the baseline scenario.

The development and maintenance of a new central database is likely to intensify energy consumption due to the operation of large-scale data servers and associated digital infrastructure. Additionally, over time, the continuous upgrading and replacement of hardware will contribute to a rise in electronic waste. However, the magnitude of this negative impact is considered negligible compared with the baseline scenario.

Security

Option 2 is expected to contribute to increase the security of citizens, businesses, and public administration in the EU only to a moderate extent, most importantly because existing problems in digital management of RRR processes could only be addressed in the medium to long-term.

Option 2 is expected to address the main shortcomings identified in the baseline scenario. The case-management would allow Member States to carry out the return process in a faster and more efficient manner, enabling better identification of irregular TCNs, including those individuals posing security threats. 

Option 2 is also expected to improve data-sharing between Member States, increasing the EU’s ability to carry out effective risk assessment, improving the capacity to identify high-risk individuals, and improving the overall effectiveness of security measures. The exchange of information directly through the RRR databases reduces the risks of inconsistencies in information exchange associated to the creation of a separate communication portal.  

Risk of errors, misuse of information, and personal data breaches is expected to reduce with Option 2 by establishing standardising readmission and reintegration case management systems across Member States, managed centrally by eu-LISA, which has extensive experience in managing large-scale IT systems. Harmonised processes and security standards would reduce inconsistencies in data handling, strengthen compliance with EU data protection rules, and enhance accountability, thereby improving the secure and reliable management of sensitive personal data. 

As can be seen in the figure below, survey data underscores the divided perception among the Member States regarding the option’s added security value. While 10 Member States consider data security to be improved under the shared EU and national systems option with central database, a similar number (11 Member States) perceive only partial, or no improvement compared to the baseline scenario (see Figure 20 - Member States’ ratings of the partially decentralised option’s impact on security (n=21) ). These mixed views reflect both optimism about centralised safeguards and concerns over potential cybersecurity risks and reduced national control.

Figure 20 - Member States’ ratings of the partially decentralised option’s impact on security (n=21)

Source: Survey conducted as part of the Digitalisation Study

Similarly, in terms of risk management, only seven Member States consider the partially decentralised option with central database to perform better, while 14 Member States see little or no added benefit.

Fundamental rights

Option 2 is expected to adhere with fundamental rights and thus not expected to have any further positive nor negative impact compared to the baseline scenario.

As illustrated in the figure below, this assessment is confirmed by the survey in which most Member States indicated that Option 2 is likely to have a similar impact on fundamental rights as the baseline scenario (see Figure 21 - Member States' ratings of the partially decentralised option’s   impact on fundamental rights compared to the baseline scenario (n=21) )).

Figure 21 - Member States' ratings of the partially decentralised option’s impact on fundamental rights compared to the baseline scenario (n=21)

Source: Survey conducted as part of the Digitalisation Study

However, new challenges might occur due to the implementation of a new central database, the adjustment of national RECAMAS across all Member States and the integration thereto of iRCMS and RIAT. While this will improve data availability and coordination, the large-scale processing and centralisation of sensitive personal data may raise concerns around data protection, including the potential for misuse, unauthorised access, or insufficient oversight.

At the same time, this policy option has the potential to foster greater procedural clarity and accountability. By enabling authorities across the EU to access up-to-date and coherent information, it may reduce administrative fragmentation and help ensure that RRR cases are processed more consistently and transparently. For the data subjects (i.e. TCNs), this could translate into more equal treatment across Member States as well as better monitoring and access to the information shared and processed about them. To fully realise these benefits while avoiding unintended consequences, robust technical and legal safeguards will be essential to uphold fundamental rights throughout implementation and use.

Feasibility

Option 2 is expected to be feasible to a moderate extent.

This is primarily because integrating a new central database with existing national systems presents significant challenges in practice, as ensuring technical compatibility and data standardisation may lead to complications that affect technical and operational feasibility.

12 Member States consider the partially decentralised option with central database as politically and legally feasible. This is mainly due to the fact that Member States can continue working in a decentralised manner and in a system preserving their national specificities (i.e. national RECAMAS). Legally, the need for a self-standing Regulation and multiple legislative amendments (such as to all regulations establishing EU Information Systems) diminish the overall feasibility of this option.

Figure 22 - Member States' ratings of the feasibility of Option 2 (n=22)

Source: Survey conducted as part of the Digitalisation Study

The results also demonstrate that the majority of Member States do not regard the technical, operational and organisational feasibility favourably but rather question it. 14 Member States consider the technical viability as hardly feasible, while 12 Member States regard operational and organisational feasibility as similarly lacking in viability. This scepticism is closely tied to the understanding that the successful implementation of this option hinges on collaboration among different stakeholders. While such collaboration can be beneficial, it also risks misalignment of priorities that could hinder progress.

This assessment by the Member States is closely related to the fact that it is seen as a technical challenge to connect national systems to the central database, as foreseen under Option 2. Furthermore, several Member States repeatedly mentioned that it would require a significant amount of organisational effort to create real consistency between all the national systems and the EU systems.

Option 3: ‘Centralised system’

Assessment of effects

Effectiveness

Option 3 is expected to achieve the specific and general objectives to a moderate extent, albeit only in the medium to long-term.

The overall effects are equal to those for Option 2, with Member States expecting similar benefits in the area of data accuracy, completeness and interoperability as well as in the field of coordination and cooperation but also significant shortcomings in terms of time needed to implement the policy option.

Overall, participants in the survey conducted as part of the Digitalisation Study explained that the introduction of Option 3 would indeed bring positive effects in comparison to the baseline scenario, which involved in particular the following aspects (clustered):

·Increased standardisation and accuracy of data and less fragmentation.

The follow-up of cases and exchange of information would be easier and faster.

Costs for Member States would decrease in the long-term.

Thus, the policy option is expected to enhance data sharing and reduce silos by establishing a central database, which is expected to significantly improve access to and the quality of information. In conjunction with the enhanced data sharing anticipated under the Return Regulation, this initiative will enable all Member States to access necessary data in a consistent manner, thereby fostering a more integrated approach to digital migration management. This is also underlined by the comparison of policy options undertaken by the Member States in the Digitalisation Study’s survey, with effectiveness-related factors scoring overall well: data sharing is expected by 15 Member States responding to that item being ‘much more’ or ‘more’ favourable than in the baseline scenario under Option 3. 14 Member States made the same assessment as regards interoperability. For automation, 12 Member States also confirmed an increased effectiveness.

The creation of a centralised system is also expected to address many of the issues associated with the current operation in silos, which primarily arise from the use of disparate national systems. By consolidating data into a single database and system, the option is expected to substantially reduce the fragmentation that hampers effective coordination and collaboration among the Member States. Furthermore, this centralised approach presents significant opportunities for the automation of processes, which can be implemented uniformly across all EU Member States, leading to greater effectiveness and consistency.

However, the effectiveness of this policy option is expected to be moderate in the short term, largely due to the time required to establish the necessary infrastructure and connect it to relevant national systems. A centralised EU case management system would face considerable difficulties in accommodating the diverse legal and procedural frameworks of Member States. Differences in national administrative structures, legal standards, and operational practices would complicate the integration of data and processes (15 Member States fully or slightly agree that difficulties will arise by integrating digital systems in existing administrative frameworks). These divergences could lead to inconsistencies, institutional resistance, and delays, as Member States may be unwilling to fully align their systems with EU-wide procedures.

The timeline for the go-live of the centralised system is likely to extend into the long term, meaning that existing problems related to data sharing and siloed operations will remain unresolved during this interim period. This delay will hinder the timely achievement of both specific and general objectives, as authorities will continue to struggle with the inefficiencies of the current systems. Member States confirmed this assumption in the Digitalisation Study’s survey by outlining that the policy option would be complex and time-intensive to develop. 11 Member States indicated that the implementation and integration complexity is ‘hardly more favourable’ or ‘similar’ to the baseline.

Moreover, Member States have criticised that national specifications cannot be taken into consideration sufficiently, significantly reducing the Member States’ leeway in adapting the system towards country-specific needs. In this regard, 15 Member States indicated in the survey that the flexibility and adaptability is ‘hardly more feasible’ or ‘similar’ to the baseline scenario. If country-specific factors, such as national legislation and operational practices, are not considered sufficiently, the system may fail to align with unique legal frameworks and operational needs, leading to challenges in compliance that hinder effective digital migration management.

Efficiency and administrative burden

The efficiency of Option 3 is expected to be moderate. Its effects are expected to materialise only in the long-term. The costs are expected to be the lowest among all policy options due to the limited costs for Member States. However, due to the long-term nature of this policy option, Member States’ ‘sunk costs’ are expected to be highest among all policy options, therefore justifying the lowest efficiency rating.

In the short-term, in particular the implementation of Option 3 is expected to be highly resource-intensive, as was confirmed by multiple Member States in the Digitalisation Study’s survey. The Member States pointed out that the benefits and practicality of the policy option do not outweigh the costs that are created during the overall implementation, given that the national systems in place would need to be fully discarded and already existing data migrated to the central system. As pointed out by one interviewee, the policy option would overall be less of a burden for the Member States but would place a high burden on eu-LISA. This is due to its leading role in the development of the central database, whose added value is questionable given that most of the relevant data is already stored in other EU Information Systems (a point already discussed for policy option 2 and still relevant here). Additionally, eu-LISA's resources are already constrained: the current workload, workspace limitations, data capacity and recruitment issues constrains the agency’s capacity to swiftly develop the system. The time and complexity required for implementation also imply that existing inefficiencies—such as insufficient sharing of information and lack of automation—will persist during the transition period, continuing to burden Member States. After being implemented, the system is expected to create additional costs (such as e.g. for training of officers and maintenance, need to connect other national relevant systems to the central system such as asylum systems), therefore not balancing out the implementation costs with what could have been expected as lower operational costs.

In the long-term it can be expected that, under a central system cooperation, data exchange between Member States would be more efficient, thus reducing the need to engage in lengthy coordination processes. In addition, a major benefit would be the central go-live and maintenance of the system, reducing the need for responsible staff in the Member States and bundling costs in one central authority at the EU-level. By centralising processes and automating functions uniformly across all EU Member States, the option holds considerable potential to enhance overall efficiency. However, this potential is conditional upon the system’s capacity to reconcile national procedural differences effectively. Without sufficient flexibility and adaptability to accommodate the specific operational and legal requirements of each Member State, the centralised system risks exacerbating inefficiencies rather than resolving them. Given the significant costs expected during development and implementation, the long-term benefits do not fully outweigh the short-term costs associated with the policy option, making this option rather inefficient.

Based on the methodology, as well as the overarching and policy option-specific assumptions provided in Section 5.3 in Annex 9, costs for the Member States, Frontex, eu-LISA and the Commission are expected to range between EUR 226.83 and 288.04 million. This includes hardware and software investments, development, as well as maintenance and support across six years. Sunk costs are estimated under Option 3 to range between EUR 689.19 and 877.16 million for seven years for 27 Member States. 

A more detailed breakdown, as well as the methodology and underlying assumptions are provided in Annex 9.

Coherence

Option 3 is expected to improve the internal coherence of EU digital migration management to a moderate extent. Option 3 is also considered to be externally coherent.

In terms of internal coherence, this policy option is expected to go beyond merely establishing minimum standards for national systems but rather to overcome national fragmentation entirely through the implementation of a centralised solution. This approach is thus expected to ensure a high level of coherence among Member States, facilitating very consistent practices and procedures across the board. The use of a single system as well as the streamlining of maintenance and support services with one agency (eu-LISA with partial support of Frontex) would reduce the need for complex coordination processes, which in turn reduces the risk for incoherencies in development, implementation and running of the system. Moreover, a central go-live could be ensured in order for all Member States to start using the system at the same time, reducing the risk for delays. However, this level of coherence can only be achieved if the system is designed to effectively accommodate the significant procedural and legal differences among Member States. Without adequate flexibility and alignment mechanisms, these divergences risk reintroducing fragmentation through uneven application, resistance, or delayed integration.

Regarding external coherence, the same effects are expected for Option 3 as those described under Option 2.

Assessment of impacts

Economic

Under Option 3, potential positive and negative economic impacts are also expected to balance each other out. The same line of argumentation as for Option 1 and 2 applies.

However, given the long term of implementation for the project, economic effects would only likely materialise in the long term under this policy option.

Societal

Option 3 is expected to have moderate positive societal impacts compared to the baseline scenario.

The same types of societal impacts can be expected to materialise as under Option 1 and 2. However, the magnitude of the impacts might be somewhat more pronounced through the establishment of the EU central database and the improvements of the effectiveness and efficiency of digital migration management over time.

Environmental

Option 3 is expected to have a limited negative environmental impact compared to the baseline scenario.

The development and maintenance of a new central database will substantially increase energy as well as material consumption and generate electronic waste. However, this is at least partially offset by the abolition of the systems at national level. However, the magnitude of this impact is considered negligible compared with the baseline scenario.

Security

Option 3 is expected to contribute to increase the security of citizens, businesses, and public administration in the EU only to a limited extent, most importantly because existing problems in digital migration management could only be addressed in the medium to long-term. However, the rating foreseen is equal to the one under Option 2 as Option 3 could potentially provide even more positive security impacts through overcoming the fragmentation of national systems.

As for Option 2, the implementation of a new central database is expected to significantly enhance the ability to monitor RRR processes, ensuring that relevant authorities have access up-to-date information. By providing up-to-date, consistent data access, this option would improve information exchange and support earlier detection of high-risk individuals.

In addition, the harmonisation of case management and standardised procedures would reduce system vulnerabilities by ensuring consistency across Member States, leading to fewer discrepancies in data handling and processing. Moreover, standardisation offers the possibility to implement robust security measures uniformly across all Member States.

Additionally, the lengthy implementation timeline means that current security gaps would persist for several years, limiting the short-term impact on EU security of this option.

Fundamental rights

Option 3 is expected to have a small negative impact on fundamental rights compared to the baseline scenario. However, no infringements of fundamental rights are overall anticipated.

This is confirmed by the survey results which indicate that a majority of the Member States envisage either no improvement or a deterioration in the fundamental rights situation under the centralised option. While a centralised system could promote consistency in applying RRR processes, potentially reducing arbitrary practices across the Member States, it may face practical limitations in accommodating the legal and procedural divergences that exist among national systems. These challenges may arise from the central database’s reliance on standardised data processing and automation, which, while promoting efficiency and alignment, may not fully reflect the varying administrative practices, legal requirements, or institutional capacities across Member States. This could make it difficult to adapt the system to existing national procedures or to take into account specific legal and procedural safeguards in national frameworks.

Figure 25 - Member States' ratings of the centralised option's impact on fundamental rights compared to the baseline scenario (n=21)

Source: Survey conducted as part of the Digitalisation Study.

In addition, and as outlined under Option 2, the shift to a fully centralised system and the replacement of national systems may introduce further challenges. While intended to enhance consistency and coordination, the large-scale processing and centralisation of personal data, including sensitive personal data, may raise concerns related to data protection, including risks of misuse, unauthorised access, or insufficient oversight.

This policy option may contribute to more transparent and efficient RRR processes by improving access to up-to-date and consistent information. It is also expected to support a more uniform application of data subject (i.e. TCN) rights across Member States by facilitating clearer communication, enhancing access to the data processed about them, and promoting more transparent treatment throughout RRR processes.

Feasibility

Option 3 is expected to be feasible only to a very limited extent, potentially triggering strong resistance from Member States. This is in particular due to the Member States not being able to build upon and use the developed and adapted system many of them have used over several years.

This aligns with the findings of the survey conducted in the context of the Digitalisation Study, with a majority of Member States indicating that the central option is hardly feasible or unfeasible across all dimensions, as can be seen in the figure below.

Figure 26 - Member States' rating of the feasibility of Option 3 (n=22)

Source: Survey conducted as part of the Digitalisation Study

As the figure shows, the technical and organisational feasibility are particularly questioned by Member States. Member States’ views do not reveal a consensus among the Member States but rather highlight the fact that the centralised option has a lot of potential for discussion and opposition. Overall, it is to be assumed that the policy option in its current form will probably not be fully accepted by the Member States.

Member States have in particular expressed shortcomings with regard to the (i) lack of flexibility for Member States to adapt the system based to national needs, (ii) high costs for data migration / loss of historical data and (iii) slow development and evolution of the system as major factors impacting the feasibility to implement such a system.

In addition, some stakeholders during the targeted interviews conducted as part of the Digitalisation Study (in particular from Member States with highly developed national systems) expressed that they are not willing to give up their national systems for RRR, given that they have made positive experiences with these systems, are well-trained in using them and do not consider the EU system to be of sufficiently added value to fully replace the national systems. 15 Member States also indicated in the Digitalisation Study’s survey that stakeholder acceptance and cooperation with regard to this policy option is ‘hardly more favourable’ or ‘similar’ to the baseline scenario, indicating lacking support in implementing this option.

Choice of policy instrument

ANNEX 8: Overview of policy options