The ongoing crisis on the Moroccan-Spanish border. Riots in Belfast. A rising re-migration debate in Italy. There is no topic that is as pervasive and politically charged as the presence of migrants, particularly in Europe. And 2026 is no exception, with the only mention that, after years of heated public and political debate, the EU has finally moved forward with what it sees as a landmark decision on migration, the Return Regulation.
Following the adoption of the regulation on 17 June, Europe’s migration policy is now entering a new phase whereby migration management will increasingly depend on partnerships beyond the EU’s borders. The new return framework, however, is not only about where and how migrants are sent. It also involves migration priorities that are beginning to reshape Europe’s relationships, funding instruments and development partnerships with countries outside the EU.
A new era of migration externalization
The Return Regulation provides for the establishment of ‘return hubs’ outside EU territory, where irregular migrants could be transferred prior to deportation. The goal is to increase the number of irregular migrants who actually leave the union after they have been ordered to do so, with the level currently deemed to be too low.
However, the terminology used is in itself controversial. Reshad Jalali, Senior Policy Officer at the European Council of Refugees and Exiles, explains: “They are not destinations where people are being returned in the ordinary sense; rather, they are third countries to which people may be deported despite having no previous connection with them.”
This distinction is important as it reflects a trend of migration externalization, seeking to transfer migration management responsibilities from the EU to partner countries outside the bloc. Many of the countries being discussed as potential partners for return arrangements already have established relationships with the EU, including through development cooperation, migration partnerships and other external assistance tools.
The search for return hub partners
Before this union-wide initiative was enacted, some European countries had already attempted to establish return hubs, most notably the British deal with Rwanda, and the Italian migrant centers in Albania. Both were ultimately abandoned due to political and legal hurdles.
Under the new EU regulation, there is as yet no specified list of countries that would host such facilities. One European minister suggested locations “may be in Africa or Asia” but “not close to European borders”, leaving much room for speculation.
Rwanda, Ghana, Senegal, Tunisia, Libya, Mauritania, Egypt, Uganda, Uzbekistan, Armenia, Montenegro, and Ethiopia are among the countries that have so far been mentioned in media reports.
However, the question is not only which countries may be politically willing to participate. According to the Return Regulation, any future arrangements would be based on agreements with third countries that meet certain legal requirements, including respect for international human rights standards and the principle of non-refoulement which guarantees that no one should be returned to a country if they risk facing torture, cruel, inhuman or degrading treatment.
The price of cooperation: incentives, pressure, conditionality
Hosting a return hub is not only legally complex to organize, but may also affect public opinion and political balance. Some governments are therefore unlikely to welcome such arrangements unless the perceived benefits outweigh the political, economic and social costs.
The Senior Program Coordinator for the Mediterranean at the German Marshall Fund of the United States, Alberto Tagliapietra, argues that the EU migration externalization measures largely rely on what he describes as a “negative conditionality” toolkit. Rather than focusing on what the EU’s plan can positively bring to partner countries, this approach focuses on what the EU might withdraw if governments refuse to cooperate, whereby the EU could reduce support or reconsider partnerships with countries that hesitate to cooperate, thus increasing pressure to participate.
This negative approach “is likely to grow in importance, with the EU and its member states seeking to apply maximum pressure”, Tagliapietra commented adding that “recent measures, such as the 2025 overhauling of instruments like the Generalized Scheme of Preferences – which allows lower-income countries to benefit from reduced or zero tariffs – enable the EU to potentially suspend trade benefits for partner countries that do not cooperate on return and readmission.”
Other development policy experts echo similar concerns. Anna Knoll, head of the migration program at the European Centre for Development Policy Management, argues that “negative conditionality” is hard to enforce. She warns against assuming that tougher conditionality will necessarily deliver results. “Negative aid conditionality has rarely been used in practice. Its effects are difficult to isolate from other diplomatic or visa levers, and its effectiveness depends heavily on whether partner governments see cooperation as serving their own interests.”
At the same time, Knoll notes that tying development funding to migration raises questions about compliance with the OECD rules governing Official Development Assistance.
Which funding instruments are on the table?
EU external partnerships are not separate from EU funding instruments. If migration becomes a stronger strategic priority in terms of relations with third countries, this could influence which nations the EU funds and on what conditions it does so. Thus, while the Return Regulation falls under the EU’s migration policy, which is under the remit of Home Affairs spending, its implementation will also depend on the Union’s external partnerships, supported through the EU’s external financing mechanisms, including the Global Europe instrument.
The Return Regulation comes as migration emerges as a more important priority within the EU’s next long-term budget. While the EU’s 2028-2034 Multiannual Financial Framework (MFF) is still under negotiation, the European Commission has proposed tripling the allocations for migration, border management and internal security to €74 billion. The largest share, about €48 billion, would be earmarked for border protection and police operations while the remaining €26 billion would be channeled to migration management.
As cooperation with third countries will be essential for establishing the return hubs, the EU’s external financing instruments are likely to play an important supporting role. Under the MFF, the budget of the Global Europe instrument, which covers external partnerships among others, is expected to stand at €200 billion.
DevelopmentAid insights: What can development organizations expect?
For development organizations, this could have practical implications. Agencies working on migration governance, return and reintegration, border management or cooperation with transit countries may see new funding opportunities emerge.
Consequently, development organizations may have to rethink not only where funding can be sourced, but also how projects are designed. Demonstrating how programs can contribute to stability, resilience or migration management could become more important in future funding calls, even for those initiatives that have traditionally been framed purely as development interventions.
Anticipating audit and compliance shifts is also advisable. NGOs might, for instance, have to prove that their local interventions do not support border entities that breach human rights or raise other sensitive issues.
Ensuring accountability and human rights safeguards
As the concept of return hubs has raised human and legal rights concerns, most civil actors have called for the entire approach to be abandoned. Yet, if, and perhaps more likely when, third countries do decide to agree to function as a return hub, humanitarian organizations will have to monitor whether international human rights standards are being respected.
Reshad Jalali argues that previous similar initiatives showed that transferring responsibility to countries outside the EU “often increases the risks of arbitrary detention, ill-treatment, chain refoulement, legal limbo and inadequate access to legal remedies”. He warns that informal arrangements, rather than formal international agreements, could “undermine transparency, democratic oversight and the rule of law”.
Although he points out that monitoring is only a partial remedy for return hubs being established in the first place, it is vital to ensure that human rights are upheld and the conditions in which the migrants find themselves are adequate. These provisos also raise the question of which country will actually be held liable for any possible violations.
All these issues must be further considered to ensure that the new regulation does not “lead to the invisibilization of migrants and accelerate the process of their dehumanization”, Jalali added.
Beyond the return hubs
Whether return hubs will become operational remains uncertain. But the Return Regulation already signals a broader policy direction: migration management is becoming an important consideration within the EU’s external partnerships. For development organizations, the challenge therefore lies in not only monitoring how the regulation is implemented, but also understanding how future funding priorities, partnerships and project design may intersect with migration objectives while continuing to uphold development and human rights principles.