Five EU states have agreed a common model for offshore "return hubs" and aim to sign a first deal with a non‑EU country this year, but rights groups and past failures in Rwanda and Albania raise sharp legal, financial and human rights questions.
Denmark and four fellow EU governments say they expect to be ready to send rejected asylum seekers to deportation centers located outside the European Union by the end of 2027, as negotiations with potential partner countries enter a decisive phase.
The announcement came after a meeting in Copenhagen on Friday (September 4) attended by the migration and interior ministers of Denmark, Germany, Austria, the Netherlands and Greece -- the so‑called "group of five" -- who agreed on a common model for so‑called "return hubs" and aim to conclude a first partnership deal with a non‑EU country around the turn of the year.
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What the ministers agreed
The five countries have aligned on a shared framework for return hubs. People whose asylum claims have been rejected, and who cannot be returned to their countries of origin e.g. because the state refuses to take them back, would be transferred to facilities on the territory of one or more third countries while awaiting deportation or further processing.
Danish Migration Minister Morten Bødskov said Denmark expects to be ready to send the first irregular migrants to a partner country by the end of 2027, adding that talks with non‑EU governments had reached a "crucial phase." German Interior Minister Alexander Dobrindt said the group wants to reach an agreement with a third country this year, enabling the hubs to become operational in 2027.
Ministers stressed that the scheme would be based on "equal and mutually beneficial partnerships," with the five EU states fully financing the hubs and potentially offering additional funding, commercial partnerships or other incentives to host countries.
They also said the project would be carried out in cooperation with international organizations such as the International Organization for Migration (IOM) and the UN Refugee Agency (UNHCR), and in full compliance with EU law and international obligations. Although a UNHCR spokesperson told Reuters that the agency had not been approached with details of a proposal and could not comment on the arrangements being discussed.
It is still unclear where the hubs will be located, but Greek Migration Minister Thanos Plevris said discussions with potential partners were "becoming deeper and more fruitful." The ministers are due to meet again in Munich at the end of September to review progress.
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Uganda and Rwanda in the spotlight
Although no partner country has been officially named, multiple reports point to Uganda and Rwanda -- both run by long‑standing autocratic governments, as the most likely candidates. Some press accounts suggest a Ugandan facility could accommodate up to 10,000 people and become operational in 2027.
Rwanda has maintained strong economic growth and low levels of street crime by regional standards, and Kigali is a key partner for the EU and member states on development, security and migration.
However, the UK Supreme Court’s 2023 ruling striking down the UK-Rwanda asylum scheme found "substantial grounds" to indicate that people sent there faced a real risk of refoulement, citing deficiencies in Rwanda’s asylum system and its broader human rights record, including reports of extrajudicial killings, disappearances and past onward removals of asylum seekers to third countries. Rights groups warn that similar risks would arise if EU return hubs were located in Rwanda without robust, enforceable safeguards and independent monitoring -- it is unclear how such safeguards can be ensured externally and on an ongoing basis.
Uganda hosts one of Africa’s largest refugee populations under a formally progressive "open‑door" policy, but its overall human rights environment has deteriorated in recent years. Authorities have cracked down on political opposition, journalists and protesters -- reinstating military trials of civilians, expanding surveillance and enacting laws that severely curtail the rights of LGBTQI people and others.
Environmental and land‑rights activists, as well as refugees in some settlements, face arbitrary arrest, violence and inadequate protection, while the refugee response remains chronically underfunded. These conditions raise acute questions about arbitrary detention, due process and the safety of vulnerable groups if Uganda were to host EU return hubs.
In the meeting, countries stressed that the facilities would be "open" rather than "camps," and were described by Dutch migration minister Bart van den Brink as "a new chance" for irregular migrants "to have a life in a partner country."
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The EU Return Regulation paves the way
The initiative rests on the new EU Return Regulation, approved by the European Parliament in June and expected to receive final Council approval in the autumn, which explicitly allows member states to set up return hubs via agreements with non‑EU countries.
Under the regulation, such agreements may only be concluded with third countries where "international human rights standards and principles […] are respected," including the principle of non‑refoulement, which prohibits sending people to places where they face persecution or serious harm. The law also requires that deportees continue to receive legal counsel, linguistic support, and be able to maintain contact with families and relevant authorities.
However, key operational details remain unclear, such as who bears responsibility for migrants once in the hubs, how long they can be held, what remedies are available if rights are violated, and how independent monitoring will work in practice. Legal experts warn these ambiguities could invite challenges before national courts and the European Court of Justice (ECJ).
Any arrangement that effectively outsources asylum processing or detention to third countries is also likely to be tested under the European Convention on Human Rights (ECHR), particularly Article 3 (prohibition of inhuman or degrading treatment) and Article 13 (right to an effective remedy).
These issues have been interpreted in cases such as M.S.S. v. Belgium and Greece (2011), where the European Court of Human Rights (ECtHR) held that Belgium violated the Convention by transferring an asylum seeker to Greece despite known systemic deficiencies in its asylum and reception system, exposing him to destitution and a real risk of onward refoulement. In another more recent ruling N.D. and N.T. v. Spain (2020), the ECtHR ruled on the lawfulness of summary expulsions at the EU’s external land border, confirming that pushbacks fall within the notion of "expulsion" under the ECHR and must respect procedural safeguards, even if the applicants had crossed irregularly.
Together, these cases underline that states cannot evade ECHR obligations by externalizing border control or asylum procedures to jurisdictions where rights protections are weaker or individual assessment might be bypassed.
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Higher risks and low returns
Rights organizations and European human rights bodies have condemned the plans as incompatible with fundamental rights and likely to create human rights vacuums for detainees. Amnesty International warned that return hubs carry a high risk of arbitrary detention, torture, ill‑treatment, forced onward returns and restrictions on due process, particularly if located in countries with poor human rights records such as Uganda and Rwanda.
The International Rescue Committee, Caritas, Save the Children and other NGOs have highlighted risks of prolonged detention in prison‑like facilities, legal limbo, and severe harms to children, including separation from caregivers and exposure to rights abuses in unfamiliar jurisdictions.
Danish Refugee Council Secretary General Charlotte Slente said it would be better to implement the EU Pact on Migration and Asylum, which focuses on stricter border screening, faster asylum and return procedures, and expanded digital systems for managing asylum claims. "Return hubs focus on a small number of returns, they will not stop people from taking even more dangerous routes, and they could violate basic human rights," Slente said.
Denmark expects to be ready to send migrants to the return hub by the end of 2027, Bødskov said.
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Human rights 'black holes' and missing guardrails
In July, the Council of Europe, a non-EU body that promotes human rights, democracy and the rule of law across the continent, said return hubs posed "considerable human rights risks."
The Council’s Commissioner for Human Rights, Michael O’Flaherty, has gone further, warning that Europe risks creating "human rights black holes" if return hubs are established without strict, enforceable safeguards. In an op‑ed and a letter to the five ministers, he argued that vague assurances of compliance with human rights law are not enough; states must commit to concrete "guardrails" to prevent rights abuses.
He set out four core requirements:
- Comprehensive risk assessment: Any initiative to establish return hubs should be preceded by a thorough assessment of direct and indirect human rights risks, based on rigorous factual and legal analysis, leading to a plan to prevent, mitigate or remedy those risks.
- Independent monitoring with suspension mechanisms: If states proceed, the hubs must be subject to adequate, independent and continuous human rights monitoring, with robust review and suspension mechanisms if violations occur.
- Legally binding agreements with enforceable rights clauses: Cooperation on return hubs should be based on legally binding agreements featuring enforceable human rights clauses, not political declarations or non‑binding memoranda.
- Public scrutiny: Risk assessments, mitigation plans, monitoring outcomes and the agreements themselves should be made public to allow parliamentary, public and judicial scrutiny.
O’Flaherty has urged Austria, Denmark, Germany, Greece and the Netherlands to put these guardrails in place before operationalizing offshore return hubs, cautioning that without them, the scheme could undermine Europe’s human rights architecture and expose individuals to arbitrary detention, refoulement and other serious violations.
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Precedents and practical hurdles
The concept echoes previous outsourcing attempts that have struggled or failed. The UK’s Rwanda scheme was ruled unlawful by the Supreme Court in 2023 over refoulement risks and later abandoned by the Labour government. Denmark itself dropped a national Rwanda plan in 2023, pivoting to a European approach. Several years earlier, from 2013 and 2018, Israel’s parallel arrangement to transfer asylum seekers to Rwanda was abandoned amid legal challenges and very low uptake.
Italy’s deal with Albania offers a recent EU example, but uptake has been far below projections. Facilities designed for around 3,000 transfers a month have reportedly handled only about 500 people in total since being converted into deportation centers in March 2025, at a cost exceeding 670 million euros. An Italian university study concluded that detaining migrants in the Albanian centers has been more expensive than hosting them on Italian soil, raising questions about whether similar offshore models can ever be cost‑effective once security, monitoring and legal safeguards are factored in.
These precedents feed skepticism among experts about whether return hubs will be legally robust, operationally feasible, or cost‑effective, or whether they will mainly serve as a political signal amid hardening migration debates across Europe. The push also highlights divisions within the EU, while the "group of five" presses ahead, other member states, including France and Spain, as well as the European Parliament have expressed deep reservations about offshore detention and the compatibility of return hubs with the Common European Asylum System.
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Looming legal challenges
For now, the five states have set a clear political timeline -- a deal around the new year, and the first transfers by the end of 2027. Whether that timetable survives legal challenges, partner‑country negotiations, and pressure from rights bodies insisting on concrete guardrails remains an open question.
Any first agreement is likely to be challenged by NGOs, affected individuals and possibly national ombudspersons before domestic administrative courts, with potential referrals to the ECJ on the interpretation of the Return Regulation and the Charter of Fundamental Rights. Parallel complaints could also reach the European Court of Human Rights (ECtHR) in Strasbourg if detainees allege violations of the ECHR.
Rights groups caution that, without enforceable safeguards, offshore hubs risk recreating the same arbitrary detention, due‑process gaps and refoulement exposure that undermined earlier Rwanda and Albania models.
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With Reuters