Central and Northern European countries such as Germany, Austria, Sweden, and Finland are accelerating the process of returning asylum seekers who reach their territories under the Dublin Regulation.[i] The plan to return asylum seekers to their first points of arrival, such as Italy and Greece, has once again made migration policies within the European Union (EU) a subject of debate. Particularly, countries where center-right coalitions are in power are adopting the path of returning asylum seekers to southern borders based on international law in order to deflect anti-immigrant rhetoric rising in their domestic public opinion.
On the other hand, Italy is responding to this Europe-wide pressure with resistance, citing its insufficient national reception capacity as the reason. This attempt by member states to transfer the responsibility for immigrants and asylum seekers to one another clearly demonstrates that the issue goes beyond an ordinary migration policy debate. Returning asylum seekers under the provisions of the Dublin Regulation shows that the phenomenon of solidarity among member states is damaged by conflicts of interest on the ground; it deepens the structural fractures between EU governments.
Italian Prime Minister Giorgia Meloni opposes return requests under Dublin and the idea of border countries unilaterally assuming responsibility, citing logistical shortcomings. Southern European border countries like Italy, Greece, and Spain stand as the natural arrival points of active and intense migration routes due to their geographical locations. According to the Dublin Regulation; the plan to transfer migrants to their country of first entry, combined with the current influx of asylum seekers from outside the EU, creates a double burden for border countries. The Pact on Migration and Asylum, which began to be implemented in all EU member states on June 12, 2026, aims to make European borders safer, increase solidarity among member states, and make asylum and return procedures more efficient.[ii]
The Pact on Migration and Asylum, implemented with the aim of solving the EU’s current migrant crises, is not fully effective against the problem in question. While the responsibility for migrants is transferred to the first country of entry where their biometric data is registered under the Dublin system; these countries are forced to face the disadvantage of their geographical locations. Under the mandatory solidarity mechanism, the New Pact allows member states that do not want to accept asylum seekers the opportunity to evade responsibility in exchange for 20,000 euros per person.[iii] Even if the Pact on Migration and Asylum develops strict rules in asylum processes, it maintains the double responsibility on border countries. While the Dublin system ties the migration burden to geographical location; the new system has transformed solidarity into a financial bargain.
The inclusion of the Netherlands, Finland, and Sweden alongside Switzerland, Germany, and Austria in the process of preventing the secondary migration wave within Europe has expanded the bloc of pressure on Italy and other border countries. In addition to diplomatic tensions between countries, the return process of asylum seekers also shows its impact in domestic political dynamics. In this context, Italy in particular faces asylum seeker returns across the EU and opposition pressure in domestic politics..[iv] Prime Minister Meloni defends the fair burden-sharing and financial targets brought by the new EU Pact on Migration and Asylum. On the other hand, the fact that Italy has rejected approximately 80,000 readmission requests since 2023 clearly reflects the doubts about the solidarity network within the Union and the efficiency of the Migration Pact. Italy’s rejection of tens of thousands of returns is the most concrete evidence of institutional gridlock and weakening solidarity within the EU.
While the EU experiences institutional fragility in its migration policies; it adopts a strategy of transferring the cost of the crisis beyond its borders. Under the leadership of Germany, Austria, the Netherlands, Denmark, and Greece, diplomatic contacts are being held with Uganda to establish cross-border migrant centers.[v] In line with this plan, it is foreseen that rather than being sent to Uganda, asylum seekers would prefer to voluntarily return to their own countries. The initiative regarding return centers in Uganda reveals that the responsibility for migration policies among member states is being transferred outside European borders. In addition to Uganda, Rwanda and Uzbekistan are also among the return centers planned to become operational in 2027.[vi] The emergence of a scenario where the asylum and refuge process will be transferred to third countries reveals that the EU’s own institutions and solidarity mechanism are inadequate against the current migration crisis.
When the opposing stances of Italy and other border countries towards returns in line with the Dublin system are considered together with the New Migration Pact’s model of solving responsibility on a commercial basis and flexible responsibility, and the plans for establishing return centers in third countries, it is clearly seen that the European Union’s migration policies are structurally prone to fragility. Although leaving the burden of migration and asylum seekers on the countries at the southern border or transferring it to countries outside the Union may seem like strategic steps, they cannot fully resolve the crisis. Furthermore, although these steps aim to lighten the burden of the asylum and refuge regime within the EU, in practice they damage the will of the states to act jointly and internally threaten the structural integrity of the Schengen free movement area, which is the greatest achievement of European integration.
When all dynamics are brought together, the secondary migration wave within the EU and the crisis brought by the Dublin system clearly reflect an institutional impasse within the Union, rather than a simple diplomatic dispute. The inability to implement the Dublin system in practice, the loss of the normative value of the phenomenon of solidarity with the Migration Pact and its relocation to a commercial basis, and the plans to transfer the burden of the crisis beyond EU borders, such as to Uganda, show that the EU cannot implement collective policies in the face of the migrant crisis. While member states adopt all legal and commercial solutions to evade responsibility; it is not only migrants who are affected by this situation, the sense of trust and the solidarity network within the EU are also damaged. Despite the adoption and implementation of legal solutions like the Dublin Regulation and the Migration Pact as well as externalization policies, the EU identity is wearing down in the face of ongoing crises and internal political pressures. Therefore, solidarity, as the institutional value of the EU, is lost behind national interests. In addition to institutional fragility, current migration policies in line with externalization practices cause management crises among states and become a direct threat to the structural integrity of the EU.
[i] “Finland joins EU countries returning asylum seekers to Italy as debate on fairness continues”, InfoMigrants, https://www.infomigrants.net/en/post/73250/finland-joins-eu-countries-returning-asylum-seekers-to-italy-as-debate-on-fairness-continues, (Date Accessed: 22.08.2026).
[ii] “Pact on Migration and Asylum enters into application on 12 June”, European Commission,http://ec.europa.eu/commission/presscorner/detail/en/ip_26_1285, (Date Accessed: 22.08.2026).
[iii] “Avrupa Parlamentosu’nun onayladığı ‘reform’ olarak anılan yeni göç anlaşması neler içeriyor?”, BBC News Türkçe, https://www.bbc.com/turkce/articles/c72pn5v03pko, (Date Accessed: 22.08.2026).
[iv] “Dispute over “Dublin Cases”-Meloni defends migration policy”, Bluewin, https://www.bluewin.ch/en/news/dispute-over-dublin-cases-meloni-defends-migration-policy-li.3571055, (Date Accessed: 22.08.2026).
[v] “Uganda emerges as migration hub”, Ekathimerini, https://www.ekathimerini.com/politics/foreign-policy/1312244/uganda-emerges-as-migration-hub/, (Date Accessed: 22.08.2026).
[vi] “EU countries eye Rwanda, Uganda, Uzbekistan for first return hubs by 2027”, Hungarian Conservative, https://www.hungarianconservative.com/articles/current/eu-return-hubs-deportation-migration-rwanda-uzbekistan-uganda/, (Date Accessed: 22.08.2026).
