Today, together with organizations from around the world, we have sent a letter to the European Commission denouncing the lack of transparency around the national implementation plans of the EU Pact on Migration and Asylum.
From December 2024 we are waiting for Member States to present their national implementation plans, after consulting civil society. However, in many countries consultations have been limited, informal and lacking transparency.
Despite repeated requests, civil society organizations from several countries have not had access to these plans, nor have we been informed about their content or direction. The letter calls on the Commission to ensure that national aircraft are accessible so that civil society can provide meaningful input before the application begins.
This is the full letter:
Subject: Communication of Member States’ National Action Plans regarding the Implementation of the Pact on Migration and Asylum
Madam President, Mr. Commissioner,
The European Pact on Migration and Asylum was adopted by the European Parliament on April 10, 2024. As outlined in your communication of June 12, 2024, each Member State is expected to involve and consult “social partners (…) and representatives of civil society organizations” and to submit, no later than December 12, 2024, its own national implementation plan specifying the actions and timeline.
Several associations in Belgium, Cyprus, Spain, France, Greece, Italy, and Malta have written to their respective authorities requesting to be included in civil society consultations. In some of these Member States, exchanges—more or less formal—have taken place, but in a limited and non-transparent manner.
These associations have approached their respective authorities to obtain the national implementation plans for the Pact. However, it appears that no national implementation plan of the Pact has been made public in these countries (Belgium, Cyprus, Spain, France, Greece, Italy, and Malta). To date, civil society organizations have therefore not been informed of the content or even the orientations of part of the national implementation plans submitted to the European Commission.
The right of access to documents is an essential component of the transparency policy implemented within European institutions, as stipulated in REGULATION (EC) No 1049/2001 of the European Parliament and of the Council of May 30, 2001, regarding public access to European Parliament, Council, and Commission documents. Paragraph 10 specifies that it is possible to access not only documents drafted by the institutions but also those received by them.
The lack of effective consultation and access to the implementation plans submitted to the European Commission has led to a series of initiatives to address this shortfall, including requests for access to documents under the aforementioned FOIA legislation, as well as actions at the national level.
The undersigned associations and networks reiterate the necessity of ensuring timely and effective access to documentation. As a necessary preliminary step, these documents, of public interest, are considered to have a crucial impact on the protection and promotion of fundamental rights, as well as on the use of EU financial resources at both national and supranational levels.
We are requesting the publication of the national implementation plans of the Pact on Migration and Asylum across the EU to allow interested associations to submit, in a timely manner, potential suggestions and observations not only at the national level but also at the European level before the finalization of the procedures concerned.
Signatory associations and networks:
11.11.11 (Belgium)
Aditus Foundation (Malta)
Anafé (France)
ARCI (Italy)
ASGI (Italy)
Association for the Social Support of Youth – Arsis (Greece)
ASTI (Luxembourg)
Caritas (Belgium)
CCFD-Terre solidaire (France)
CEAR (Spain)
Center for Legal Aid – Voice in Bulgaria
Centre for Peace Studies (Croatia)
CGIL (Italy)
Ciré (Belgium)
CNCD – 11.11.11 (Belgium)
Comisiones Obreras – CCOO (Spain)
Cyprus Refugee Council (Chypre)
Equal Legal Aid (Greece)
Euromed Rights
European Network on Statelessness (UK)
Fenix Humanitarian Legal Aid (Greece)
Gisti (France)
Greek Forum of Refugees (Greece)
Greek Council for Refugees (Greece)
International rescue committee – IRC (Belgium)
IRIDIA (Spain)
Italian Council for Refugees (Italy)
JRS Belgium
JRS France
JRS Malta
Kisa (Cyprus)
La Cimade (France)
Ligue de l’enseignement (France)
Médecins du Monde (Belgium)
Médecins du Monde – Europe
Migreurop
Mobile Info Team (Greece)
Nansen (Belgium)
NGO Legis from North Macedonia
Picum
Por Ti Mujer Association (Spain)
Rete Nazionale Europasilo (Italy)
Salud por Derecho (Spain)
Servicio Jesuita a Migrantes (Spain)
Statewatch (UK)
Vluchtelingenwerk Vlaanderen (Belgium)
