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EUROPEAN COMMISSION

Brussels, 27.10.2026 COM(2026) 1037 final

2026/0340 (COD)

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

{SEC(2026) 1037 final} - {SWD(2026) 1037 final} - {SWD(2026) 1038 final} -

{SWD(2026) 1039 final}

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The functioning and the sustainability of the European migration and asylum system rely on a

comprehensive system that manages migration in the long term. The effective return of third

country nationals who have no right to stay in the European Union (‘EU’ or ‘Union’) is

indispensable to the integrity of the European system.

As part of the new approach to migration presented in the European Strategy on Asylum and

Migration(1), the EU has now strong rules and more modern rules in place on return. The new

Return Regulation(2) strengthens the common approach to return through more effective

procedures, enhanced cooperation between Member States and with third countries, and tools

to support the implementation of returns. The simplification and automation of return

processes can then further contribute to reducing the administrative burden and workload of

national authorities, leading to simplification and increasing the efficiency of the return

system. The Return Regulation works hand-in-hand with the rules of the Pact on Migration

and Asylum, which close the loopholes between asylum and return, including through the

procedures at the external borders, and reinforce the cooperation between different authorities,

within and among Member States, with European Union agencies and with third countries.

The EU has made progress in strengthening the effectiveness of return. In 2025, Member

States issued 487 285 orders to leave and 136 665 illegally staying third-country nationals

were effectively returned, corresponding to a return rate of 28%. While this return rate marks

a clear improvement compared to 2024 (24% return rate), there remains significant progress

to make to ensure that all third-country nationals ordered to leave are effectively returned.

Against this background, the Commission is taking additional steps to further improve the

effectiveness of returns by presenting this new initiative establishing a common digital

backbone, connecting the relevant authorities, processes and tools. In addition, alongside this

initiative, the Commission is equally proposing to revise the Frontex mandate to significantly

strengthen its role as the Union actor in the common system for returns. Together with the

new Return Regulation, these initiatives reflect the EU’s enhanced ambition to have swift and

effective returns, as an integral component of a well-managed EU migration system.

Digitalisation is important tool in the EU’s toolbox to make returns more effective, support

the implementation of the new common EU system for returns put in place by the Return

Regulation, and reduce administrative burden. By enabling more efficient procedures and

coordination, as well as more reliable data collection, digital systems are crucial to effectively

design, enforce and monitor migration policy and rules. They contribute to achieving modern,

secure and efficient tools to improve the quality, consistency and timeliness of decision

making on return, and to enhance enforcement. Digitalisation will help make information

available where and when it is needed, automate processes, reduce manual work and

administrative burden, facilitate cooperation between authorities, and improve the monitoring

(1) European Commission, Communication from the Commission to the European Parliament and the

Council: European Asylum and Migration Management Strategy, COM(2026) 45 final, 26 January

2026. (2) Regulation (EU) 2026/2280 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, (OJ L, 2026/2280, 15.10.2026, ELI:

http://data.europa.eu/eli/reg/2026/2280/oj).

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and implementation of returns. The digitalisation of case management in the area of return,

readmission and reintegration is thus an important enabler of the common EU system for

returns, complementing the strengthened operational role of Frontex on return and helping

translate the EU’s enhanced ambition in the field of return into more coordinated, efficient

and effective action.

Despite significant efforts at national and EU levels during the last years, the digital landscape

for return-related case management remains fragmented, with uneven development, wide

differences in the availability of data, its functionalities and interoperability, as well as limited

data sharing. First, the information needed to carry out efficiently return, readmission and

reintegration is not easily accessible to all relevant authorities. The available data necessary to

swiftly complete these processes is not sufficiently shared and accessible within the same

Member State, between Member States (and between Member States and Frontex), and

between Member States (or Frontex) and third countries. Second, migration authorities are

suffering from excessive administrative burden. Third, more granular and swiftly available

statistics on return, readmission and reintegration are needed.

These problems are caused by three main drivers. In the first place, the digitalisation of case

management in the area of return, readmission and reintegration remains insufficient and

fragmented across the EU. National return systems vary widely in availability, functionality,

and interoperability, and are often disconnected from existing EU tools for readmission and

reintegration. Governance is similarly fragmented, with responsibilities divided across

Member States, EU agencies, and third-country partners, leading to inconsistent standards,

complex data protection arrangements, and dependence on external funding and cooperation.

Secondly, even when digital case management systems are in place and integrated, the

functionalities of these systems are often inadequate. Key features such as adjusting

deadlines, or automatic follow-up of return decisions are rarely implemented. Technical

limitations, such as the lack of connection to Schengen Information System or a single

identifier for returnee, can lead to duplicate cases and unreliable statistics. Thirdly, the lack of

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

the use of existing IT systems and prevents the development of new systems.

Against this background, the objectives of this proposal are to support a more effective and

efficient implementation of the rules on return, readmission and reintegration of third-country

nationals staying illegally in the Union, laid down in the Return Regulation, and contribute to

the implementation of the new approach to migration. By providing the digital means

necessary to support the implementation of the new common rules, the proposal will

contribute to making the common system for returns more efficient and operational in

practice, with simpler and more automated workflows that reduce administrative burden. In

the long-term, this would be the first step towards a comprehensive, integrated and digitalised

EU migration management system, that would go beyond return, readmission and

reintegration processes and may encompass other migration processes such as asylum.

The initiative aims to enhance data sharing between competent authorities, in compliance with

data protection rules, to ensure that the information necessary to carry out and monitor return,

readmission and reintegration processes is available; to significantly decrease the

administrative burden and workload of national authorities; to advance with the digitalisation

of return, readmission and reintegration processes and remedy the limited functionalities of

existing IT systems to ensure that processes and reporting requirements are more digitalised,

simplified, and more automated; and to improve data collection to enable the automated

creation of more accurate and granular statistics and their timely availability.

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• Consistency with existing policy provisions in the policy area

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 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.

The EU Strategy on Voluntary Return and Reintegration(4) and the Operational Strategy for

More Effective Returns of the EU Return Coordinator(5) raised 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(6) and the CWP for 2026(7) 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. The long-

term European Asylum and Migration Management Strategy 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.

The Return Regulation identifies digital systems for managing return, readmission and

reintegration processes as one of the components of the common system for returns(8),

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 return, readmission and reintegration 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.

In parallel, the Commission is presenting a proposal to review the mandate of Frontex to also

broaden its role as the Union actor in the common system for returns. The revised mandate

will entrust the Agency with the necessary responsibilities and capabilities to contribute to the

digitalisation of return, readmission and reintegration, creating synergies with this proposal

and helping to establish the common digital backbone needed for a more integrated, efficient

and effective return system across the Union.

(3) Ursula von der Leyen, Political Guidelines for the Next European Commission 2024–2029, Strasbourg,

18 July 2024. (4) European Commission, Communication from the Commission to the European Parliament and the

Council: The EU strategy on voluntary return and reintegration; COM(2021) 120 final, 27 April 2021. (5) European Commission, Policy Document: Towards an operational strategy for more effective returns;

COM(2023) 45 final, of 24 January 2023. (6) European Commission, Communication from the Commission to the European Parliament, the Council,

the European Economic and Social Committee and the Committee of the Regions; Commission work

programme 2025 Moving forward together: A Bolder, Simpler, Faster Union, COM/2025/45 final,

11.2.2025. (7) European Commission, Communication from the Commission to the European Parliament, the Council,

the European Economic and Social Committee and the Committee of the Regions; Commission work

programme 2026 Europe's Independence Moment, COM(2025) 870 final, 21.10.2025. (8) Article 40(1)(c) of the Return Regulation.

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• Consistency with other Union policies

The proposal aligns with 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. Where relevant, the functionalities of the newly established

systems should make use of artificial intelligence systems, in compliance with Regulation

(EU) 2024/1689 of the European Parliament and of the Council(9).

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• 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’). This article 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

return, readmission and reintegration is a means to this end.

Additionally, the proposal is based on Article 77(2)(b) and (d) of the TFEU to enable the

targeted amendment of Regulation (EU) 2019/817 of the European Parliament and of the

Council of 20 May 2019(10). Article 77(2)(b) and (d) of the TFEU mandates the European

Parliament and the Council to adopt measures concerning the checks to which persons

crossing external borders are subject and any measure necessary for the gradual establishment

of an integrated management system for external borders.

• Subsidiarity (for non-exclusive competence)

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. This would hinder the

implementation of common rules on return, including the new Return Regulation, 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.

(9) Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying

down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No

167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives

2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act) (Text with EEA

relevance) (OJ L, 2024/1689, 12.7.2024, ELI: http://data.europa.eu/eli/reg/2024/1689/oj). (10) 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 (OJ L 135, 22.5.2019, p. 27, ELI:

http://data.europa.eu/eli/reg/2019/817/oj).

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• Proportionality

To address the problems identified, the proposal envisages a solution based on a partially

decentralised approach, which will build on existing systems at national and EU level.

For the management of return cases, this solution will provide Member States with the

flexibility to base their return case management systems ('national RECAMAS') either on a

model document and specifications developed by Frontex (‘RECAMAS Model’), or on an IT

reference implementation, made of several digital modules, developed by Frontex and based

on the RECAMAS Model (‘Frontex RECAMAS’), or a combination of the two. This

approach will allow Member States to build on prior investments, while ensuring convergence

towards a common framework.

The case management systems in the area of readmission ('iRCMS') and reintegration

('RIAT') will be provided at EU level.

By building on existing systems and relying on a partially decentralised approach, the

proposal does not go further than what is necessary to solve the problems identified.

• Choice of the instrument

A regulation is the most suitable instrument to achieve the desired policy objectives given the

objective of establishing a new integrated digital case management system both at national

and EU level.

Regulations are binding, directly applicable in all Member States and ensure uniform rules

across the EU. The existing problems of fragmentation and inconsistencies in relation to the

digital management of return, readmission and reintegration processes are to a very large

degree caused by diverging national approaches. Therefore, a regulation best addresses those

problems.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

Not Applicable

• Stakeholder consultations

A thorough and broad consultation process was conducted with all relevant stakeholders in

2025.

Interviews took place with national authorities from EU Member States and Schengen

Associated Countries, relevant EU agencies and institutions (eu-LISA, Frontex, European

Data Protection Supervisor), as well as civil society organisations, international organisations,

academia, and reintegration partners.

Three different written surveys targeted at three types of stakeholders (i.e. national authorities

of EU Member States and Schengen Associated Countries, civil society organisations and

international organisations) have been conducted.

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.

On 30 September 2025, a workshop took place with representatives from the Member States,

Schengen Associated Countries and the Commission.

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On 9 December 2025, the Commission held a stakeholder meeting with representatives from

Member States, Schengen Associated Countries and Frontex.

• Collection and use of expertise

Not Applicable.

• Impact assessment

An impact assessment is accompanying the proposal.

• Regulatory fitness and simplification

Not Applicable

• Fundamental rights

As part of the impact assessment, the impact of the proposed measures on fundamental rights

has been assessed. The proposal is found to adhere to fundamental rights.

Risks may arise in case the governance of the different IT systems is not defined sufficiently

clearly, thereby leading to difficulties to identify the roles and responsibilities of the different

data processors and controllers, as well as the applicable data protection rules. These risks are

mitigated by laying down clear provisions on the governance of the systems and on the

corresponding applicable rules. Roles and responsibilities under data protection rules will be

clearly allocated (i.e. who is controller, who is processor).

Compliance with the General Data Protection Regulation and the Data Protection Regulation

for EU institutions, bodies, offices and agencies is ensured. Several safeguards, including

encryption, access controls, and audit logging are provided by the proposal.

4. BUDGETARY IMPLICATIONS

As detailed in the accompanying legislative financial and digital statement, the investments

required at the EU level and Member States level are compatible with the proposed 2028-

2034 Multiannual Financial Framework (MFF) and could be financed during the 2028-2034

MFF.

To develop and improve their national RECAMAS, Member States will be able to make use

of the funds allocated under their national programmes in accordance with the Proposal for a

Regulation of the European Parliament and of the Council establishing the Union support for

asylum, migration and integration for the period from 2028 to 2034(11).

The development and maintenance of Frontex RECAMAS, iRCMS, RIAT and a secure

communication channel ('the communication portal') will be financed by the EU budget.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

The legal proposal includes provisions for monitoring and evaluation based on the following

indicators.

Specific Objective 1: enhancing data sharing

(11) Proposal for a Regulation of the European Parliament and of the Council establishing the Union support

for asylum, migration and integration for the period from 2028 to 2034, COM/2025/540 final.

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• Number of datasets on return, readmission and reintegration cases requested by

Member States and made available to other Member States within the applicable

time limits laid down by the Return Regulation.

• Number of readmission requests processed via the iRCMS.

Specific Objective 2: digitalising, automating and simplifying return, readmission and

reintegration processes

• Number of national RECAMAS in place.

• Number of Member States making use of the Frontex RECAMAS, or parts of it.

• Number of national RECAMAS having integrated iRCMS and RIAT.

• Number of national RECAMAS connected to the European Search portal ('ESP'), the

Central Repository for reporting and Statistics ('CRRS') and the Schengen

Information System ('SIS').

• Number of national RECAMAS connected to the communication portal.

• Number of sub-processes streamlined or automated.

• Average duration of the processing time per return, readmission and

reintegration case.

• Number of staff trained in new procedures and IT systems.

Specific Objective 3: enabling the creation of accurate statistics

• Number of statistical datasets (as per the Return Regulation) created automatically.

• Number of statistical datasets (as per the Return Regulation) provided within the

applicable time limits laid down by the Return Regulation.

The application of the new rules will also be monitored through the Schengen evaluation and

monitoring mechanism.

• Detailed explanation of the specific provisions of the proposal

The first chapter relates to general provisions (Article 1 to 6). It lays down the subject matter

of the Regulation (Article 1) and the relevant definitions (Article 2). It establishes the IT

architecture made of several digital components (Article 3) and the objectives of the

digitalisation of case management in the area of return, readmission and reintegration (Article

4). It clarifies the role of existing EU Information Systems and interoperability components

(Article 5), and of other national relevant IT systems (Article 6).

The second chapter (Article 7 to 14) relates to case management systems and addresses the

questions of the recording (Article 7), consultation (Article 8), rectification and erasure of

data (Article 9). It lays down the common functional features that the three future IT systems

on return, readmission and reintegration should have (Article 10) and the specific essential

functional features that each separate system should have: the national return case

management system ('national RECAMAS') (Article 11), the EU integrated readmission case

management system ('iRCMS') (Article 12) and the EU reintegration case management

system ('RIAT') (Article 13). It establishes the communication channel between migration

authorities ('communication portal') (Article 14).

The third chapter relates to the development and operation of the systems and corresponding

responsibilities (Article 15 to 26). Roles and responsibilities are defined for the development

phase (Article 15) and the corresponding IT governance is established via the creation of a

Program Management Board, mirroring what is usually done for the development of other IT

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systems (Article 16). Roles and responsibilities are defined for the operational management of

the systems (Article 17) and specific provisions are included on data security (Article 18), the

keeping of logs (Article 19), data retention (Article 20), the rights of data subjects (Article

21), statistics (Article 22), the responsibility for personal data processing (Article 23), staff

training (Article 24), the required cooperation between national data protection supervisory

authorities and the European Data Protection Supervisor (Article 25) and penalties for non-

compliance with the Regulation (Article 26).

The fourth chapter addresses the targeted amendments of other Union legal acts (Articles

27 to 30) and more specifically:

• 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), as

eu-LISA mandate will be expanded to support Frontex and establish the

communication portal (Article 27).

• 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 (Article 28).

• Regulations (EU) 2019/817 and (EU) 2019/818 of the European Parliament and of

the Council of 20 May 2019 establishing a framework for interoperability between

EU information systems, to ensure that the Central Repository for Reporting and

Statistics can be connected to national systems, and to allow the newly established

communication portal to be also used to exchange information to support the

resolution of links identified by the Multiple Identity Detector (Article 29 and 30).

The fifth chapter contains the final provisions, addressing the question of costs (Article 31),

requiring Member States to notify the competent authorities to the Commission (Article 32),

and providing for a phased applicability per system and per Member State to ensure a gradual

start of operations (Article 33). It includes a provision on the committee procedure (Article

34) and it establishes the Advisory Group, which will provide some technical support to the

Program Management Board (Article 35). It requires Member States to provide for contact

points (Article 36) and defines the monitoring and evaluation measures (Article 37). The

Regulation should enter into force on the twentieth day following that of its publication in the

Official Journal of the European Union (Article 38).

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2026/0340 (COD)

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

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular

Article 77(2), points (b) and (d), and Article 79(2), point (c), thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national Parliaments,

Having regard to the opinion of the European Economic and Social Committee(1),

Having regard to the opinion of the Committee of the Regions(2),

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) The sustainability of the Common European Asylum System and the good functioning

of the Schengen area rely on the ability to build a comprehensive system that manages

migration in the long term. An effective return policy is a key component of a credible

migration management system.

(2) The Pact on Migration and Asylum aims at building such system, and it relies on swift

and clear processes as well as close and interlinked cooperation between different

authorities, within and among Member States, with Union agencies and with third

countries. The Pact legislation establishes a seamless link between asylum and return

procedures to increase the efficiency and coherence of the asylum and migration

system as a whole.

(3) Regulation (EU) 2026/2280 of the European Parliament and of the

Council(3) establishing a common system for the return of third-country nationals

staying illegally in the Union, identifies digital systems for managing return,

readmission and reintegration of third country nationals as key components of the

common system for returns.

(4) The Commission, the European Union Agency for the Operational Management of

Large-Scale IT Systems in the Area of Freedom, Security and Justice (‘eu-LISA'),

established by Regulation (EU) 2018/1726 of the European Parliament and of the

(1) OJ C [...], [...], p. [...] (2) OJ C [...], [...], p. [...] (3) Regulation (EU) 2026/2280 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, OJ L, 2026/2280, 15.10.2026, ELI:

http://data.europa.eu/eli/reg/2026/2280/oj).

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Council(4), the European Border and Coast Guard Agency (‘Frontex’), established by

Regulation (EU) 2019/1896 of the European Parliament and of the Council(5), the

European Union Agency for Asylum, established by Regulation (EU) 2021/2303 of

the European Parliament and of the Council(6), and Member States have made

significant investments in the development and implementation

of information technology (‘IT’) systems in the field of migration management.

(5) In the field of case management in the area of return, readmission and reintegration,

the availability, level of digitalisation and functionalities of IT systems vary

significantly between Member States. Existing IT systems for return, readmission and

reintegration at national and Union level have been developed separately and by

different actors, resulting in a fragmented digital landscape with limited

interoperability and data-sharing possibilities.

(6) The current legal and operational framework limits the effective exchange and

management of information throughout the return process and creates inefficiencies in

the handling of return, readmission and reintegration procedures, as well as

administrative burden. It is therefore necessary to establish a coherent framework for

digital systems in the area of return, readmission and reintegration in order to support

the establishment of a common Union system for returns.

(7) All Member States should make use of national return case management systems

(‘national RECAMAS’) ensuring that return procedures are systematically and swiftly

carried out. For the purpose of ensuring a minimum level of effectiveness and

efficiency, national RECAMAS should either be based on a model document and

specifications developed by Frontex (‘RECAMAS Model’), or on an IT reference

implementation developed by Frontex and based on the RECAMAS Model (‘Frontex

RECAMAS’), or on a combination of the RECAMAS Model and specific digital

modules of the Frontex RECAMAS. Member States may develop their national

RECAMAS while integrating in it some specific modules from the Frontex

RECAMAS, such as an application to communicate with third-country nationals

subject to a return procedure. Member States choosing to adopt the Frontex

RECAMAS or some of its modules should integrate them in their own digital

environment and further customise it to their own needs. The Frontex RECAMAS

should be provided to Member States as a standalone non-production IT system. As a

result, the Frontex RECAMAS should not run in a live production environment and

should not contain personal data.

(8) In order to facilitate swift and effective cooperation with third countries and third

parties located in third countries in the context of readmission and reintegration

procedures, in compliance with the applicable rules on international transfers of

personal data and in due respect of the fundamental rights of data subjects, it is

necessary to establish, at Union level, an integrated readmission case management

(4) 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 (OJ L 295 21.11.2018, p. 99,

ELI: http://data.europa.eu/eli/reg/2018/1726/oj). (5) 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, (OJ L 295, 14.11.2019, p. 1, ELI: http://data.europa.eu/eli/reg/2019/1896/oj). (6) Regulation (EU) 2021/2303 of the European Parliament and of the Council of 15 December 2021 on the

European Union Agency for Asylum and repealing Regulation (EU) No 439/2010, (OJ L 468, p. 1, ELI:

http://data.europa.eu/eli/reg/2021/2303/oj).

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system ('iRCMS') and a Union reintegration case management system ('RIAT'). Those

systems should enable the secure management and exchange of information required

for the identification of third-country nationals, the issuance of travel documents, the

organisation of return operations, and the handling of reintegration and post-arrival

assistance. In particular, iRCMS should be used to manage readmission procedures

and may be connected to third countries’ digital readmission case management

systems for those purposes. RIAT should be used to manage reintegration procedures

and should allow third parties competent for reintegration assistance to consult and

record relevant data. In order to ensure an efficient and seamless use of those systems

by authorised users, without requiring them to log off and log on when accessing

different systems, iRCMS and RIAT should be integrated into the national

RECAMAS.

(9) The European Search Portal (ESP), established by Regulations (EU) 2019/817 (7) and (EU) 2019/818(8) of the European Parliament and the Council, facilitates the

access and the querying of the EU information systems referred to in Article 4, point

15, of Regulation (EU) 2019/817 and in Article 4, point 15, of Regulation (EU)

2019/818 ('EU information systems'). The ESP should facilitate the fast,

seamless, efficient, systematic and controlled access, by Member State authorities and

Union agencies, to those systems by enabling simultaneous querying. Member States

authorities, such as migration authorities, and Union Agencies should use the ESP to

query those systems where necessary for the performance of their tasks in accordance

with their access rights under the legal instruments governing those systems.

(10) Accurate and reliable statistics are necessary to ensure the proper monitoring and

assessment of the efficiency of return, readmission and reintegration processes. The

Common Repository for Reporting and Statistics (‘CRRS’) provides for the possibility

to generate statistics from EU information systems. As the CRRS is a statistical tool

that already exists at Union level, it would be efficient, for the purpose of avoiding the

duplication of digital tools, to also make use of this digital tool to allow for the

creation of accurate and reliable statistics in the area of return, readmission and

reintegration. Therefore, the CRRS should be able to create such statistics from

national RECAMAS, iRCMS and RIAT and should therefore be amended

accordingly. Statistics should be accessible to competent authorities, Frontex, eu-

LISA, and the Commission in accordance with their respective responsibilities.

(11) In several Member States, existing return case management systems are linked to other

national relevant systems and databases, such as asylum case management systems or

information systems supporting judicial authorities, which contain data directly or

indirectly supporting the management of return readmission and reintegration cases. In

other Member States, return case management systems are being developed.

Consequently, Member States should be allowed to maintain and develop those

(7) 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 (OJ L 135, 22.5.2019, p. 27, ELI:

http://data.europa.eu/eli/reg/2019/817/oj). (8) 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 (OJ L 135, 22.5.2019, p. 85, ELI:

http://data.europa.eu/eli/reg/2019/818/oj).

EN 12 EN

connections and ensure that their national RECAMAS is designed in such a way that it

can allow the connection to other national relevant systems, in accordance with

national law and in respect of the fundamental right to privacy and data protection.

(12) Competent authorities, other national authorities and Frontex should be allowed to

record in return, readmission and reintegration case management systems all data,

including personal data, necessary to complete effectively those procedures. The data

should be limited to what is necessary to effectively manage return, readmission and

reintegration cases and each authority should ensure that the data it records is accurate

and up to date.

(13) Based on anonymised data, competent authorities, other national authorities, and

Frontex should ensure the provision of reliable and accurate statistics in the area of

return, readmission and reintegration.

(14) All processing operations of personal data undertaken under this Regulation should

comply with Regulations (EU) 2016/679(9) and (EU) 2018/1725(10) of the European

Parliament and of the Council, as applicable.

(15) Competent authorities should have direct access only to the data they recorded in

national RECAMAS, iRCMS and RIAT. However, where it emerged from the use of

the European Search Portal or from the use of iRCMS or RIAT that the same third-

country national is subject to several return cases in several Member States, any

competent authority having recorded data on this third country national should, upon a

request as referred to in Article 36 of Regulation (EU) 2026/2280, be provided by the

other competent authority concerned with the data recorded regarding this third-

country citizen, for the purpose of processing the case. Where applicable, the

requested data should be exchanged through a secure communication channel ('the

communication portal'). Upon agreement of the competent authority which recorded

the data, Frontex should be able to consult the data recorded in national RECAMAS,

in iRCMS, and in RIAT, only for the purposes for which the data was recorded.

(16) Competent authorities and Frontex should have the obligation and the technical

possibility to rectify and erase inaccurate, incomplete or unlawfully recorded data that

they recorded. When personal data are concerned, such obligation should be carried

out in compliance with applicable data protection rules. If a competent authority or

Frontex becomes aware that another competent authority has recorded factually

inaccurate data, it should inform the competent authority having recorded the data of

the inaccuracy as soon as possible. Such information should be transmitted via the

communication portal.

(17) To ensure a minimum level of efficiency of return, readmission and reintegration case

management systems, functional requirements should be established. These

functionalities should enable the allocation of a single identifier per case and effective

case handling, including automated case creation, identity verification, and real-time

tracking of procedural statuses and deadlines, retrieval of data from the Schengen

(9) Regulation (EU) 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) (OJ L 119, 4.5.2016,

p. 1). (10) 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 (OJ L 295, 21.11.2018, p. 39).

EN 13 EN

Information System, secure data exchange with third countries, and competent

authorities, while facilitating digital communication with third-country nationals,

automation of key procedures, such as the initiation of readmission applications,

issuance of return decisions, generation of alerts in the Schengen Information System

and creation of the European Return Order in the Schengen Information System, IT-

supported reintegration case management, including financial management, quality

assurance, and performance monitoring of assistance programs, as well as mechanisms

for complaints and incident tracking, operational tools for flight booking, travel

document management, and logistical coordination to facilitate the practical

implementation of return operations, and analytics capabilities to anticipate case

fluctuations, generate statistics for monitoring purposes, and ensure transparency in

the application of return policies. Where deemed relevant during the development

phase, the systems' functionalities should make use of artificial intelligence systems, in

compliance with Regulation (EU) 2024/1689 of the European Parliament and of the

Council(11).

(18) The necessary data to manage return, readmission and reintegration cases is not always

available in EU information systems, either because the data cannot be recorded in EU

information systems, for instance because some categories of data relating to prima

facie evidence of nationality in the context of readmission procedures are too specific

to be stored in Eurodac or in the Schengen Information System, or because the data

has not yet been recorded in or has already been deleted from EU information systems.

In those cases, and where necessary, Member States should have the possibility to

share swiftly and securely the data necessary to manage return, readmission and

reintegration cases. Single points of contact should coordinate and facilitate such

exchanges.

(19) A communication portal should be established to provide the technical means for

Member States' single points of contact and Union agencies to share swiftly, securely

and efficiently the data necessary for the management of return, readmission and

reintegration cases where such data is not available in the relevant EU information

systems. The communication portal should connect all national RECAMAS as well as

Frontex through the integrated return management platform ('IRMA'), thereby

facilitating the effective exchange of data. Member States should use the

communication portal where the sharing of such data is necessary for the performance

of their tasks and in accordance with their respective access rights and applicable data

protection rules.

(20) Frontex should build on its own expertise and continue to develop the RECAMAS

Model. As a frequent user of existing readmission case management systems and the

main user of RIAT, Frontex is in the best position to take responsibility for the

development, technical evolutions and operational management of iRCMS and

RIAT. As return case management systems will remain at national level, Member

States should continue to take responsibility for the development, technical evolutions

and operational management of national RECAMAS.

(21) When developing the communication portal, the reuse of existing well-functioning

digital infrastructures for the communication of data between migration authorities

(11) Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying

down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No

167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives

2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act) (Text with EEA

relevance) (OJ L, 2024/1689, 12.7.2024).

EN 14 EN

should be favoured as this would allow a faster technical implementation of the

communication portal and would contribute to reducing its financial costs.

Consequently, the communication portal may be based on existing digital

infrastructure currently under the responsibility of eu-LISA, such as the digital

infrastructure underpinning the SIRENE or the DublinNet systems. eu-LISA should

therefore take responsibility for the development, technical evolutions and operational

management of this secure communication channel, as well as on the monitoring of

developments in research relevant for operational management. In order to update eu-

LISA’s mandate as well as to entrust it with the role of supporting Frontex on the

development of the Frontex RECAMAS, iRCMS and RIAT, Regulation should be

amended accordingly.

(22) The digital exchange of information with third countries involved in readmission

procedures contributes to a more efficient cooperation and facilitate the timely

handling of readmission cases. Where the relevant arrangements with a third country

provide for such digital exchanges, Frontex should therefore put in place the necessary

technical arrangements, upon request by the Commission, to enable the secure

transmission of the information concerned. Such cooperation should be limited to the

information necessary for the individual readmission case and should not provide the

third country with general access to the iRCMS or to the information held therein.

(23) To ensure an effective cooperation of all stakeholders and the adequate management

and coordination of the development phase of the RECAMAS model, the Frontex

RECAMAS, iRCMS, RIAT and the communication portal, a Program Management

Board should be established. It should be composed of 10 Members appointed by the

Frontex Management Board, the eu-LISA Management Board, the Executive

Directors of Frontex and eu-LISA and the Commission. The Program Management

Board should meet regularly until the start of operations of all national RECAMAS,

iRCMS, RIAT and the communication portal. The Program Management Board

should continue to meet after the start of operations. The Program Management Board

should prepare reports on a regular basis and should share those reports with the

Frontex Management Board and the eu-LISA management Board.

(24) Ensuring a high level of security for national RECAMAS, iRCMS, RIAT, and the

communication portal is necessary because these systems process sensitive operational

and personal data whose compromise could endanger individuals' rights, safety and

privacy. It is also essential to preserve the confidentiality, integrity and availability of

information exchanged between Member States, Frontex and eu-LISA, thereby

maintaining trust and the effective functioning of return management cooperation.

Therefore, Member States, Frontex and eu-LISA should ensure a high level of data

security for the systems for which they are responsible. To that end, Member States,

Frontex, and eu-LISA should implement technical and organisational measures to

protect personal data and other data processed in those systems against accidental or

unlawful destruction, loss, alteration, unauthorised disclosure of, or access to such

data. Those measures should, in particular, ensure physical protection, access control,

storage control, user control, data access control, communication control, control of

data recording, transport control, recovery, reliability, integrity and self-auditing,

including the automatic detection, within 24 hours, of relevant events that may

indicate a security incident.

(25) In order to ensure the lawfulness of data processing, to guarantee data integrity and

security and to enable effective supervision, all data processing operations carried out

in national RECAMAS, iRCMS, RIAT and in the communication portal should be

EN 15 EN

logged. Competent authorities, data protection supervisory authorities and, where

appropriate, Frontex and eu-LISA should have access to the logs to the extent

necessary for the performance of their respective tasks.

(26) The personal data recorded in national RECAMAS, iRCMS and RIAT should be kept

for no longer than is necessary for the purposes for which the data are processed. A

10-year retention period is operationally necessary to enable the competent authorities

to identify, monitor, and assess return-related cases over time, including where

individuals reappear under different identities, and to ensure continuity of case-

handling across procedures and authorities. It is also needed to support the preparation,

issuance, recognition and enforcement of return decisions, entry bans and related

follow-up measures, including the verification of compliance, the management of re-

entry risks and the handling of subsequent applications or appeals, as well as to

prevent abuse of reintegration assistance schemes, including repeated applications in

different Member States. Where the duration of an entry ban exceeds 10 years,

retention for the duration of that ban is necessary to allow the authorities to verify and

enforce the ban effectively and to maintain an accurate record for border management,

migration control and public security purposes. To ensure that the data is effectively

deleted, the systems should provide for an automated erasure of the data once the

retention period has elapsed. Given that Frontex does not issue return decisions,

specific rules and a shorter retention period should apply to Frontex, as provided for in

Regulation (EU) …/… of the European Parliament and of the Council [EBCG

Regulation].

(27) Data subjects should be effectively able to exercise their rights in accordance with

Regulations (EU) 2016/679 and (EU) 2018/1725.

(28) Regulation (EU) 2018/1725 should apply to the processing of personal data by Frontex

and eu-LISA pursuant to this Regulation, while Regulation (EU) 2016/679 should

apply to the processing of personal data by Member States pursuant to this Regulation.

This Regulation respects the fundamental rights and principles recognised by the

Charter of Fundamental Rights of the European Union. In particular, the processing of

personal data under this Regulation should be carried out in accordance with the

applicable data protection rules and in a manner that ensures the full respect of those

rights and principles.

(29) In order to support operational monitoring, relevant statistical data from national

RECAMAS, iRCMS and RIAT should be recorded in an automated manner in

the CRRS.

(30) In order to ensure accountability and effective data protection governance in the

operation of RECAMAS, iRCMS, RIAT and the communication portal, it is necessary

to specify the roles of the authorities involved in the processing of personal data. The

allocation of governance roles should reflect the operational responsibilities and

technical capacities of the actors involved for each system concerned. Accordingly,

Member States should designate the national authority acting as controller for data

entered in the national RECAMAS and for their operational management, while

Frontex should act as data processor where it records data in these systems. For

iRCMS, each Member State should be considered as controller in relation to the

processing of data it records in this system. Frontex should be considered as processor

in relation to the processing of data it records in iRCMS, and for its operational

management. For RIAT, each Member State should be considered as controller in

relation to the processing of data it records in this system on cases from national

EN 16 EN

reintegration assistance programs. Member States and Frontex should be considered as

joint controllers in relation to the processing of personal data recorded in RIAT for

cases managed under an EU reintegration assistance program. Frontex should be

considered processor in relation to the processing of data it records on cases from

national reintegration assistance programs managed in RIAT and for the operational

management of RIAT. For the communication portal, Member States and Frontex

should be considered joint controllers in relation to the processing of personal data

exchanged through the communication portal. eu-LISA should be considered as

processor in relation to the operational management of the communication portal.

(31) In order to ensure the secure and lawful operation of national RECAMAS, iRCMS,

RIAT and the communication portal, staff of competent authorities, Frontex and eu-

LISA who are authorised to access those systems should receive appropriate and

regular training.

(32) Certain data contained in the Schengen Information System relevant for return,

readmission and reintegration purposes may need to remain available to Member

States for the continued management of return cases after the corresponding alert has

been deleted from the system. Such information may be necessary for the

identification of the person and for establishing their previous return history where the

person subsequently re-enters the territory of the Member States and becomes subject

to a new return procedure. Retaining relevant information in national systems in

accordance with the applicable data protection and retention rules governing national

RECAMAS would ensure its availability for such subsequent procedures and facilitate

the identification of the person, including where a return decision was issued by

another Member State and subsequently recognised in accordance with the applicable

rules on mutual recognition. Member States should therefore have the possibility to

access and keep the data contained in alerts on return referred to in Article 4 of

Regulation (EU) 2018/1860 of the European Parliament and of the Council(12). Since

that possibility presupposes access to alerts on return, it should be applied by Member

States that use the Schengen Information System pursuant to Regulation (EU)

2018/1860. Particular attention should be given to the quality of the data in the

Schengen Information System. Where a Member State has relevant additional or

modified data, or it has evidence suggesting that data is factually incorrect or has been

unlawfully stored, it should inform through supplementary information exchange the

alert issuing Member State in line with established procedures in order for the data

contained in the alert to be completed, modified or deleted. Regulation (EU)

2018/1860 should therefore be amended accordingly.

(33) To ensure efficient, secure, and standardised communication between the Member

States’ authorities and between those authorities with the ETIAS Central Unit set up

pursuant to Article 7 of Regulation (EU) 2018/1240 of the European Parliament and of

the Council(13), the communication portal should serve also as a channel for

communication required under Regulations (EU) 2019/817 and (EU) 2019/818. The

use of the communication portal for this purpose would allow a faster technical

(12) 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

(OJ L 312, 7.12.2018, p. 1, ELI: http://data.europa.eu/eli/reg/2018/1860/oj). (13) 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 (OJ L 236, 19.9.2018, p. 1).

EN 17 EN

implementation of a means of communication. Regulations (EU) 2019/817 and (EU)

2019/818 should therefore be amended accordingly.

(34) In order to ensure the effective, secure and orderly start of operations of national

RECAMAS, iRCMS, RIAT and the communication portal, it is necessary to provide

for a flexible approach as regards the date from which those systems are to be

used. Member States should be required to have in place and use a national

RECAMAS by four years from the date of entry into force of this Regulation at the

latest and to notify the Commission and Frontex of the date on which they start using

it. In order to ensure a uniform and reliable start of operations of the different

components of the overall architecture, the completion of the development of iRCMS,

RIAT and the communication portal should be determined by the Commission by

means of implementing acts, following the successful completion of comprehensive

tests. On this basis, Member States should, within prescribed time limits, take the

necessary measures to integrate iRCMS, RIAT and the communication portal into

their national RECAMAS and notify the Commission and Frontex of the successful

integration. Frontex should likewise take the necessary measures to integrate the

communication portal into IRMA and notify the Commission accordingly. The start of

operations of iRCMS, RIAT and the communication portal in the Member States

concerned, and their operation by Frontex where applicable, should then be

determined by the Commission by means of implementing acts, on the basis of

declarations of successful integration and comprehensive testing. The Commission

should inform the European Parliament and the Council of the relevant dates so

determined, and those implementing acts should be published in the Official Journal of

the European Union. Member States and, where applicable, Frontex should start using

iRCMS, RIAT and the communication portal from the dates so determined.

(35) To develop and improve their national RECAMAS, Member States should benefit

from Union financial support in accordance with [Regulation .../... of the European

Parliament and of the Council establishing the Union support for asylum, migration

and integration for the period from 2028 to 2034]. The development and maintenance

of Frontex RECAMAS, iRCMS, RIAT and the communication portal should be

financed by the EU budget.

(36) Since the objectives of the Regulation, namely to improve the efficiency of case

management in the area of return, readmission and reintegration through

digitalised tools and interoperable systems, thereby contributing to the effective

functioning of the area without internal borders, cannot be sufficiently achieved by the

Member States but can rather, by reason of the scale or effects of the action to ensure a

common and coherent approach among Member States, be better achieved at Union

level, the Union may adopt measures, in accordance with the principle of subsidiarity

as set out in Article 5 of the Treaty on European Union. In accordance with the

principle of proportionality as set out in that Article, this Regulation does not go

beyond what is necessary in order to achieve those objectives.

(37) In order to ensure uniform conditions for the implementation of this Regulation,

implementing powers should be conferred on the Commission to specify technical and

operational requirements for the uniform application of the functional features of

national RECAMAS, iRCMS and RIAT, to specify the technical requirements

necessary for the connection to the communication portal, to specify the technical

requirements necessary for the recording in the CRRS, as well as the specific types of

data needed for the recording of data on cases status and to specify the formats for

communications via the communication portal. Those powers should be exercised in

EN 18 EN

accordance with Regulation (EU) No 182/2011 of the European Parliament and of the

Council(14).

(38) In accordance with Articles 1 and 2 of the Protocol No 22 on the position of Denmark,

as annexed to the TEU and to the TFEU, Denmark is not taking part in the adoption of

this Regulation and is not bound by it or subject to its application. Given that this

Regulation builds upon the Schengen acquis, Denmark should, in accordance with

Article 4 of that Protocol, decide within a period of six months after the Council has

decided on this Regulation whether it will implement it in its national law.

(39) [Ireland is taking part in this Regulation in accordance with Article 5(1) of Protocol

No 19 annexed to the TEU and to the TFEU and Article ... of Council Decision

.../... [Council decision adopted on the basis of Article 4 of Protocol No 19].] or [This

Regulation constitutes a development of the provisions of the Schengen acquis in

which Ireland does not take part in accordance with Protocol No 19 on the Schengen

acquis integrated into the framework of the European Union, annexed to the Treaty on

European Union and the Treaty on the Functioning of the European Union, and,

subject to the application of Article 4 of that Protocol, Ireland is not bound by it or

subject to its application.]

(40) As regards Iceland and Norway, this Regulation constitutes a development of the

provisions of the Schengen acquis within the meaning of the Agreement concluded by

the Council of the European Union and the Republic of Iceland and the Kingdom of

Norway concerning the latter’s association with the implementation, application and

development of the Schengen acquis, which fall within the area referred to in Article

1, point A of Council Decision 1999/437/EC(15).

(41) As regards Switzerland, this Regulation constitutes a development of the provisions of

the Schengen acquis within the meaning of the Agreement between the European

Union, the European Community and the Swiss Confederation on the Swiss

Confederation’s association with the implementation, application and development of

the Schengen acquis which fall within the area referred to in Article 1, point A of

Decision 1999/437/EC read in conjunction with Article 3 of Council Decision

2008/146/EC(16).

(42) As regards Liechtenstein, this Regulation constitutes a development of the provisions

of the Schengen acquis within the meaning of the Protocol between the European

Union, the European Community, the Swiss Confederation and the Principality of

Liechtenstein on the accession of the Principality of Liechtenstein to the Agreement

between the European Union, the European Community and the Swiss Confederation

on the Swiss Confederation’s association with the implementation, application and

(14) Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

laying down the rules and general principles concerning mechanisms for control by the Member States

of the Commission's exercise of implementing powers (OJ L 55, 28.2.2011, p. 13, ELI:

http://data.europa.eu/eli/reg/2011/182/oj). (15) Council Decision 1999/437/EC of 17 May 1999 on certain arrangements for the application of the

Agreement concluded by the Council of the European Union and the Republic of Iceland and the

Kingdom of Norway concerning the association of those two States with the implementation,

application and development of the Schengen acquis (OJ L 176, 10.7.1999, p. 31, ELI:

http://data.europa.eu/eli/dec/1999/437/oj). (16) Council Decision 2008/146/EC of 28 January 2008 on the conclusion, on behalf of the European

Community, of the Agreement between the European Union, the European Community and the Swiss

Confederation on the Swiss Confederation’s association with the implementation, application and

development of the Schengen acquis (OJ L 53, 27.2.2008, p. 1, ELI:

http://data.europa.eu/eli/dec/2008/146/oj).

EN 19 EN

development of the Schengen acquis which fall within the area referred to in Article 1,

point A of Decision 1999/437/EC read in conjunction with Article 3 of Council

Decision 2011/350/EU(17).

(43) As regards Cyprus, this Regulation constitutes an act building upon, or otherwise

related to, the Schengen acquis within the meaning of Article 3(1) of the 2003 Act of

Accession.

(44) The European Data Protection Supervisor was consulted in accordance with Article

42(2) of Regulation (EU) 2018/1725 and delivered its opinion on […]

HAVE ADOPTED THIS REGULATION:

Chapter 1

GENERAL PROVISIONS

Article 1

Subject matter

This Regulation lays down rules relating to the digitalisation of case management in the area

of return, readmission and reintegration, in particular rules on digital case management

systems, their development, operation and responsibilities of authorities operating them.

Article 2

Definitions

For the purposes of this Regulation, the following definitions apply:

(1) 'EU information systems' means the large-scale IT systems referred to in

Article 4, point (15), of Regulation (EU) 2019/817 and in Article 4, point 15, of

Regulation (EU) 2019/818;

(2) 'centralised system’ means a system in which control, decision-making, or data

processing is concentrated in a single central authority;

(3) 'federated system’ means a system in which separate entities retain legal and

operational independence, while cooperating under a common framework,

protocol, or set of rules;

(4) 'third-country national' means third-country national as defined in Article 3,

point (1), of Regulation (EU) 2026/2280;

(5) 'return decision' means return decision as defined in Article 3, point (4), of

Regulation (EU) 2026/2280;

(6) 'competent authority' means any of the competent authorities referred to in

Article 41 of Regulation (EU) 2026/2280;

(17) Council Decision 2011/350/EU of 7 March 2011 on the conclusion, on behalf of the European Union,

of the Protocol between the European Union, the European Community, the Swiss Confederation and

the Principality of Liechtenstein on the accession of the Principality of Liechtenstein to the Agreement

between the European Union, the European Community and the Swiss Confederation on the Swiss

Confederation’s association with the implementation, application and development of the Schengen

acquis, relating to the abolition of checks at internal borders and movement of persons (OJ L 160,

18.6.2011, p. 19, ELI: http://data.europa.eu/eli/dec/2011/350/oj).

EN 20 EN

(7) 'competent authority of origin' means the competent authority which records

the data in its national return case management system (national RECAMAS),

in the integrated Union readmission case management system (iRCMS) or in

the Union reintegration case management system (RIAT);

(8) 'case' means the digital file created in national RECAMAS, in iRCMS or in

RIAT relating to the return, readmission and, where applicable, reintegration of

a third-country national;

(9) 'multiple cases' means two or more cases in two or more Member States

relating to the same third-country national;

(10) ‘IT reference implementation’ means a single or a set of reusable IT solutions,

including their documentation, developed to support Member States in the

implementation of this Regulation and designed to be further customised by the

Member States to their specific operational needs;

(11) ‘other national relevant IT systems' means IT systems directly or indirectly

supporting the management of cases in national RECAMAS, iRCMS and

RIAT, including asylum systems, information systems supporting judicial

authorities, foreigners’ databases, national flight booking systems, criminal

information systems, automated fingerprint identification systems.

Article 3

Technical architecture

1. The digitalisation of case management in the area of return, readmission and

reintegration shall be ensured through the establishment, functioning and effective

use of:

(a) national return case management system, which may be centralised or

federated, in each Member State (‘national RECAMAS’);

(b) an integrated Union readmission case management system, integrated in each

national RECAMAS (‘iRCMS’);

(c) a Union reintegration case management system, integrated in each national

RECAMAS (‘RIAT’);

(d) the European Search Portal (‘ESP’) established by Regulations (EU) 2019/817

and (EU) 2019/818;

(e) the Central Repository for Reporting and Statistics (‘CRRS’) established by

Regulations (EU) 2019/817 and (EU) 2019/818;

(f) the communication portal referred to in Article 14, providing for a

communication infrastructure as a secure communication channel between the

authorities using the different national RECAMAS.

2. Member States shall develop their national RECAMAS based on one of the

following:

(a) a model document and specifications developed by the European Border and

Coast Guard Agency (‘Frontex’) (‘RECAMAS Model’);

(b) an IT reference implementation, made of several digital modules, developed by

Frontex and based on the RECAMAS Model, which shall be adopted by

EN 21 EN

Member States and further customised to their specific operational needs

(‘Frontex RECAMAS’);

(c) a combination of the RECAMAS Model and specific digital modules of the

Frontex RECAMAS, as detailed in the RECAMAS Model.

Article 4

Objectives of the digitalisation of case management in the area of return, readmission

and reintegration

The objectives of the digitalisation of case management in the area of return, readmission and

reintegration shall be to:

(a) support the implementation of a common Union system for returns in

compliance with Regulations (EU) 2024/1349 of the European Parliament and

of the Council(18) and (EU) 2026/2280;

(b) support competent authorities in the issuance and implementation of return

decisions, in compliance with Regulations (EU) 2024/1349 and (EU)

2026/2280;

(c) support competent authorities in the handling and implementation of

readmission, in compliance with Regulations (EU) 2024/1349 and (EU)

2026/2280;

(d) support competent authorities in the handling and implementation of the

provision of reintegration assistance, in compliance with Regulations (EU)

2024/1349, (EU) 2026/2280 and (EU) …/… [EBCG Regulation];

(e) provide reliable and accurate statistics on return, readmission and reintegration,

including for the purposes of monitoring and evaluation, informing evidence-

based policymaking and operational use, in compliance with Regulations (EU)

2024/1349 and (EU) 2026/2280.

Article 5

EU information systems

In order to facilitate the processing of data referred to in Article 7 and the identification of

multiple cases, each competent authority using national RECAMAS, the iRCMS and RIAT

shall make use of the ESP to access EU information systems in accordance with the legal

instruments governing those EU information systems and with Regulations (EU) 2019/817

and (EU) 2019/818.

Article 6

Connection to other national relevant IT systems

For the purposes of connecting the national RECAMAS to other national relevant IT systems

in accordance with national law, Member States shall ensure the technical compatibility

between the national RECAMAS and those systems for the prompt, secure and effective

transmission of data to and from those systems.

(18) 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 (OJ L, 2024/1349, 22.5.2024,

ELI: http://data.europa.eu/eli/reg/2024/1349/oj).

EN 22 EN

Chapter 2

CASE MANAGEMENT SYSTEMS

Article 7

Recording of data in national RECAMAS, in iRCMS and in RIAT

1. Competent authorities, shall record, where available, in national RECAMAS, in

iRCMS and in RIAT the data referred to in Article 36(6) of Regulation (EU)

2026/2280 that are adequate, relevant and limited to what is necessary for ensuring

compliance with Regulations (EU) 2024/1349, (EU) 2026/2280 and (EU)…/…

[EBCG Regulation].

2. Subject to the agreement of a competent authority, Frontex shall record, where

available, in national RECAMAS, in iRCMS and in RIAT the data referred to in

paragraph 1 of this Article in the exercise of its powers and in the performance of its

tasks in accordance with Section [8] of Regulation (EU) …/… [EBCG Regulation].

3. Each competent authority, and, where applicable, Frontex shall be responsible for

ensuring that the data it records in national RECAMAS, in iRCMS and in RIAT are

accurate and up to date.

4. In RIAT, Frontex, when implementing a Union reintegration assistance program,

may grant to third parties competent for reintegration assistance the right to record

data relating to reintegration referred to in Article 36(6) of Regulation (EU)

2026/2280. Third parties competent for reintegration assistance shall be responsible

for ensuring that the data they record in RIAT are accurate and up to date.

Article 8

Consultation of data recorded in national RECAMAS, in iRCMS and in RIAT

1. Each competent authority of origin may consult in national RECAMAS, in iRCMS

and in RIAT only the data it recorded.

2. Subject to the agreement of the competent authority of origin, Frontex may consult

the data recorded in national RECAMAS, in iRCMS and in RIAT in the exercise of

its powers and in the performance of its tasks in accordance with Section [8] of

Regulation (EU) …/… [EBCG Regulation].

3. Where a third-country national is the subject of multiple cases, any competent

authority of origin concerned shall, upon a request as referred to in Article 36(3) of

Regulation (EU) 2026/2280, be provided with the recorded data on that third-country

national by the other competent authority of origin concerned. Where applicable, in

accordance with Article 36(3) of Regulation (EU) 2026/2280, those data shall be

exchanged through the communication portal.

4. In RIAT, Frontex, when implementing a Union reintegration assistance program,

may grant to third parties competent for reintegration assistance the right to consult

data relating to reintegration referred to in Article 36(6) of Regulation (EU)

2026/2280.

EN 23 EN

Article 9

Rectification and erasure of data recorded in national RECAMAS, in iRCMS and in

RIAT

1. Each competent authority of origin or Frontex shall, without delay, rectify or erase

any inaccurate, incomplete or unlawfully recorded data it recorded in national

RECAMAS, in iRCMS or in RIAT. Only the competent authority of origin or

Frontex that recorded such data shall be authorised to rectify or erase it.

2. If a competent authority has information suggesting that data recorded in national

RECAMAS, in iRCMS and in RIAT is inaccurate, incomplete or unlawfully

recorded, it shall inform via the communication portal the competent authority of

origin or, where applicable, Frontex as soon as possible.

3. If Frontex has information suggesting that data recorded in national RECAMAS, in

iRCMS and in RIAT by a competent authority of origin is inaccurate, incomplete or

unlawfully recorded, it shall inform via the communication portal the competent

authority of origin as soon as possible.

4. Third parties competent for reintegration assistance shall, without delay, rectify or

erase any inaccurate, incomplete or unlawfully recorded data they recorded in RIAT.

If a third party competent for reintegration assistance has information suggesting that

data recorded in RIAT is inaccurate, incomplete or unlawfully recorded, it shall

inform Frontex as soon as possible.

Article 10

Functional features of national RECAMAS, iRCMS and RIAT

1. National RECAMAS, iRCMS and RIAT shall provide for the following functional

features:

(a) issuance of a single identifier allocated to each third-country national for whom

a case is opened as regards return, readmission and, where applicable,

reintegration;

(b) possibility to automate the creation of a case upon the ending of legal stay of a

third-country national;

(c) identification of multiple cases via the search in EU information systems in line

with the corresponding access rights and via iRCMS and RIAT;

(d) automatic retrieval of the necessary data referred to in Article 7 between

national RECAMAS, iRCMS and RIAT;

(e) possibility to access the data contained in alerts on return referred to in Article

4 of Regulation (EU) 2018/1860 and in the European Return Order referred to

in Article 5(13) of Regulation (EU) 2026/2280;

(f) possibility to access the data referred to in Article 27(4) and Article 28(4) of

Regulation (EU) 2024/1358 of the European Parliament and of the Council(19);

(19) 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

EN 24 EN

(g) possibility to customise national RECAMAS, iRCMS and RIAT in order to

adjust the systems to procedural workflows and associated deadlines applicable

under legal and administrative requirements;

(h) possibility to monitor applicable deadlines and prioritise cases;

(i) possibility for competent authorities and third-country nationals to securely

communicate and exchange documents via digital means, including the use by

third-country nationals of a dedicated mobile application;

(j) possibility to securely exchange the data referred to in Article 7 via the

communication portal between competent authorities and between competent

authorities and Frontex;

(k) access to relevant national, Frontex and eu-LISA training material on return,

readmission and reintegration and on the use of national RECAMAS, iRCMS

and RIAT;

(l) possibility to assign one or several statuses to each case, corresponding to the

stage and type of procedure ('case status'), including the possibility to update

the case status in case of annulment or suspension of the return decision;

(m) possibility to have an overview and breakdown of all cases, in particular per

third-country and case status;

(n) possibility to transmit the relevant information to information systems

supporting the work of judicial authorities;

(o) possibility to automate the creation of data reports that are relevant to the

production of statistics referred to in Regulation (EU) 2026/2280 and in Article

7 of Regulation (EC) No 862/2007 of the European Parliament and of the

Council(20);

(p) predictive analysis to anticipate fluctuations in the number of cases, based on

current and past aggregated or anonymised statistical data;

(q) possibility to organise return operations through one or several flight booking

systems.

2. The RECAMAS Model shall set out the details of the functional features referred to

in paragraph 1.

3. The Commission may adopt implementing acts specifying the technical and

operational requirements necessary for the uniform application of the functional

features set out in paragraph 1 of this Article. Those implementing acts shall be

adopted in accordance with the examination procedure referred to in Article 34(2).

Article 11

Functional features of national RECAMAS

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 (OJ L, 2024/1358, 22.5.2024, ELI:

http://data.europa.eu/eli/reg/2024/1358/oj). (20) Regulation (EC) No 862/2007 of the European Parliament and of the Council of 11 July 2007 on

Community statistics on migration and international protection and repealing Council Regulation (EEC)

No 311/76 on the compilation of statistics on foreign workers (Text with EEA relevance) (OJ L 199,

31.7.2007, p. 23, ELI: http://data.europa.eu/eli/reg/2007/862/oj).

EN 25 EN

1. National RECAMAS shall provide for the following functional features:

(a) technical support to manage the registration of third-country nationals;

(b) technical support to manage initial checks and verifications, including

vulnerability checks;

(c) technical support to manage the identification and confirmation of the identity

and nationality of third-country nationals;

(d) access to the list referred to in Article 12(3) of Regulation (EU) 2017/2226 of

the European Parliament and of the Council(21);

(e) support to the preparation, issuance and notification of return decisions and

removal orders;

(f) possibility to automate the creation and update of the European Return Order in

the Schengen Information System, in compliance with Regulations (EU)

2018/1860, (EU) 2018/1861 and (EU) 2026/2280;

(g) possibility to automate the creation and update of alerts on return and for

refusal of entry and stay in the Schengen Information System, in compliance

with Regulations (EU) 2018/1860 and (EU) 2018/1861;

(h) management of measures for the prevention of absconding, detention and

alternatives to detention referred to in Chapters III, IV and VI of Regulation

(EU) 2026/2280;

(i) possibility to transfer a case from the return border procedure applicable under

Regulation (EU) 2024/1349 to the return procedure applicable under

Regulation (EU) 2026/2280.

2. The RECAMAS Model shall set out the details of the functional features referred to

in paragraph 1.

3. The Commission may adopt implementing acts specifying the technical and

operational requirements necessary for the uniform application of the functional

features set out in paragraph 1 of this Article. Those implementing acts shall be

adopted in accordance with the examination procedure referred to in Article 34(2).

Article 12

Functional features of iRCMS

1. iRCMS shall provide for the following functional features:

(a) possibility to automate the initiation of readmission following the issuance of

an enforceable return decision;

(b) possibility to automate the creation of a readmission application;

(c) possibility to securely communicate and exchange the data referred to in

Articles 37, 38 and 39 of Regulation (EU) 2026/2280 with third countries’

(21) 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 (OJ L 327,

9.12.2017, p. 20, ELI: http://data.europa.eu/eli/reg/2017/2226/oj).

EN 26 EN

competent authorities, including through the connection to a third country’s

digital system and direct secure messaging and including the possibility to

organise and conduct identification interviews through iRCMS;

(d) possibility to manage cases based on national and Union readmission

instruments or established practices;

(e) possibility to receive the outcome of nationality verification and of the

establishment of identity from third countries’ competent authorities;

(f) possibility to receive and print emergency travel documents;

(g) possibility to book and manage flights, including through the possibility to

communicate with third parties competent for other tasks related to

implementing the return.

2. The RECAMAS Model shall set out the details of the functional features referred to

in paragraph 1.

3. The Commission may adopt implementing acts specifying the technical and

operational requirements necessary for the uniform application of the functional

features set out in paragraph 1 of this Article. Those implementing acts shall be

adopted in accordance with the examination procedure referred to in Article 34(2).

Article 13

Functional features of RIAT

1. RIAT shall provide for the following functional features:

(a) access to relevant information on third countries where the reintegration

assistance will be provided, including on the content of the available

reintegration assistance;

(b) possibility for a competent authority of origin, when implementing a national

reintegration assistance program, and for Frontex, when implementing a Union

reintegration assistance program, to grant to third parties competent for

reintegration assistance the right to record, consult, rectify and erase data

relating to reintegration referred to in Article 7, in accordance with Article

7(4), Article 8(4) and Article 9(4);

(c) possibility for a competent authority to communicate with third parties

competent for reintegration assistance on individual cases;

(d) possibility to book and manage flights, including through the possibility to

communicate with third parties competent for other tasks related to

implementing the return;

(e) possibility to implement, monitor and financially manage reintegration

assistance, including via tracking the budget consumption of reintegration

assistance programs;

(f) possibility to have an overview of the reintegration assistance provided to

specific third country nationals, covering both the Union and national

reintegration assistance programs, based on the data entered by Member States

and Frontex;

(g) possibility to manage cases from Union and national reintegration assistance

programs;

EN 27 EN

(h) possibility to create statistics on reintegration, including to assess the quality of

reintegration assistance;

(i) possibility to manage outward referral to further reintegration assistance

programs and national reintegration schemes of third countries;

(j) possibility to perform quality assurance checks on reintegration assistance

cases, including the assessment of reintegration plans, monitoring of follow-up

actions, and recording of approval and audit trails;

(k) possibility to monitor the performance of third parties competent for

reintegration assistance, including indicators related to responsiveness,

implementation of reintegration plans, completion of cases, and absorption of

available financial support;

(l) possibility to record and manage complaints and incidents related to the

provision of reintegration assistance, including the tracking of remedial actions

and ensuring appropriate access control and traceability.

2. The RECAMAS Model shall set out the details of the functional features referred to

in paragraph 1.

3. The Commission may adopt implementing acts specifying the technical and

operational requirements necessary for the uniform application of the functional

features set out in paragraph 1 of this Article. Those implementing acts shall be

adopted in accordance with the examination procedure referred to in Article 34(2).

Article 14

Communication portal

1. The communication portal shall be established to facilitate the sharing of data

referred to in Article 36 of Regulation (EU) 2026/2280, without affecting its use for

other purposes provided for under Union law.

2. The communication portal shall be integrated into each national RECAMAS and into

the integrated return management platform ('IRMA') referred to in Article [57] of

Regulation (EU) …/… [EBCG Regulation].

3. In each competent authority, a single point of contact shall have access to the

communication portal. Single points of contact shall be competent for coordinating

and facilitating the exchange of data in compliance with Article 36 of Regulation

(EU) 2026/2280.

4. The Commission may adopt implementing acts specifying the technical requirements

necessary for the integration of the communication portal in the national RECAMAS

of the Member States. Those implementing acts shall be adopted in accordance with

the examination procedure referred to in Article 34(2).

Chapter 3

DEVELOPMENT, OPERATION AND RESPONSIBILITIES

Article 15

Development and technical evolutions

EN 28 EN

1. Frontex shall be responsible for the development of the RECAMAS Model, as well

as for its evolutions, in compliance with Article [55] of Regulation (EU) …/…

[EBCG Regulation].

2. Frontex shall be responsible for the development, including the design, of the

Frontex RECAMAS, iRCMS and RIAT, as well as for technical evolutions, in

compliance with Article [55] of Regulation (EU) …/… [EBCG Regulation], with the

support of eu-LISA.

3. Member States shall be responsible for the development, including the design, of

national RECAMAS, as well as for technical evolutions. Member States shall be

responsible for the integration of iRCMS and RIAT into their national RECAMAS

with the support of Frontex, in compliance with Article [55] of Regulation (EU)

…/… [EBCG Regulation]. Where applicable, Member States shall be responsible for

the integration and customisation of the Frontex RECAMAS or of some of its

modules.

4. eu-LISA shall be responsible for the development, including the design, as well as

for technical evolutions, of the communication portal. Member States shall be

responsible for the integration of the communication portal into their national

RECAMAS, with the support of eu-LISA.

5. Frontex, eu-LISA and Member States shall cooperate and coordinate their work.

6. Technical developments shall take into account any relevant Interoperable Europe

solutions, as referred to in Article 7 of Regulation (EU) 2024/903 of the European

Parliament and of the Council(22).

Article 16

Program Management Board

1. During the development phase of the RECAMAS Model, the Frontex RECAMAS,

iRCMS, RIAT and the communication portal, a Program Management Board

composed of 10 members shall be established. It shall be composed of

(a) three members appointed by the Frontex Management Board from among its

members or alternate members;

(b) three members appointed by eu-LISA’s Management Board from among its

members or alternate members;

(c) a member representing eu-LISA appointed by its Executive Director;

(d) a member representing Frontex appointed by its Executive Director;

(e) two members appointed by the Commission.

During the development phase, the Program Management Board shall meet regularly

and at least six times per year until the start of operations of all national RECAMAS,

iRCMS, RIAT and the communication portal. It shall ensure the adequate

management and coordination of the development phase of RECAMAS Model, the

Frontex RECAMAS, iRCMS, RIAT and the communication portal. The

(22) Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying

down measures for a high level of public sector interoperability across the Union (Interoperable Europe

Act) (OJ L, 2024/903, ELI: http://data.europa.eu/eli/reg/2024/903/oj).

EN 29 EN

Program Management Board shall submit written reports every month to Frontex and

eu-LISA’s Management Boards on the progress of the program.

2. From the start of operations in all Member States set in accordance with Article 33,

the Program Management Board shall meet at least one time per year. It shall ensure

the adequate management and coordination of the technical evolutions of the

RECAMAS Model, the Frontex RECAMAS, iRCMS, RIAT and the communication

portal.

3. The Program Management Board shall have no decision-making power nor any

mandate to represent the Frontex or eu-LISA’s Management Boards.

4. The Frontex Management Board shall establish the rules of procedure of the

Program Management Board which shall include in particular rules on:

(a) its chairmanship;

(b) meeting venues;

(c) the preparation of meetings;

(d) the admission of experts to meetings;

(e) communication plans ensuring full information to non-participating members

of Frontex and eu-LISA’s Management Board.

5. The chairmanship of the Program Management Board shall be held by a Member

State which is fully bound under Union law by the legislative instruments governing

the development, establishment, operation and use of the EU Information

Systems. The chair shall be one of the members appointed by Frontex Management

Board referred to in paragraph 1, first subparagraph, point (a).

6. All travel and subsistence expenses incurred by the members of the

Program Management Board appointed by Frontex Management Board and by the

Executive Director of Frontex shall be paid by Frontex. All travel and subsistence

expenses incurred by the members of the Program Management Board appointed by

eu-LISA Management Board and by the Executive Director of eu-LISA shall be paid

by eu-LISA. Frontex shall provide the Program Management Board with a

secretariat.

7. During the development phase, the Advisory Group referred to in Article 35 shall

meet regularly, and at least six times per year, until the start of operations of all

national RECAMAS, iRCMS, RIAT and the communication portal. It shall report

after each meeting to the Program Management Board. It shall provide the technical

expertise to support the tasks of the Program Management Board and shall follow up

on the state of preparation of Frontex, the Member States and eu-LISA.

Article 17

Operational management

1. Frontex shall be responsible for the operational management of iRCMS and RIAT.

2. Where a working arrangement concluded by Frontex with the competent authority of

a third country in accordance with Article [88] of Regulation (EU) …/… [EBCG

Regulation] provides for the digital exchange of data necessary for the purpose of

readmission in accordance with Articles 37, 38 and 39 of Regulation (EU)

2026/2280, Frontex shall, at the request of the Commission, take the necessary

EN 30 EN

measures to establish and maintain a secure connection between the iRCMS and the

relevant digital system of that third country to facilitate such exchanges. The data

exchanged shall be limited to those strictly necessary for the readmission procedure

applicable between the Member State concerned and the third country. The third

country shall not have access to the iRCMS or to any data other than those

exchanged in relation to an individual readmission case.

3. Member States shall be responsible for the operational management of national

RECAMAS.

4. eu-LISA shall be responsible for the operational management of the communication

portal.

5. Operational management shall consist of all the tasks necessary to ensure the

uninterrupted availability of national RECAMAS, iRCMS, RIAT and the

communication portal, in accordance with this Regulation.

6. Frontex, eu-LISA and Member States shall ensure that at all times the best available

technology, subject to a cost-benefit analysis, is used for national RECAMAS,

Frontex RECAMAS, iRCMS, RIAT and the communication portal.

Article 18

Data security

1. Frontex shall ensure the security of iRCMS and RIAT. Member States shall ensure

the security of the national RECAMAS. eu-LISA shall ensure the security of the

communication portal. In particular, Frontex, eu-LISA and Member States shall:

(a) physically protect the data, including by making contingency plans for the

protection of critical infrastructure;

(b) deny unauthorised persons access to data-processing equipment and national

installations in which the Member State carries out operations in accordance

with the purposes of national RECAMAS, RIAT, iRCMS or the

communication portal (equipment, access control and checks at entrance to the

installation);

(c) prevent the unauthorised reading, copying, modification or removal of data

media (data media control);

(d) prevent the unauthorised input of data and the unauthorised inspection,

modification or erasure of stored personal data (storage control);

(e) prevent the use of automated data-processing systems by unauthorised persons

using data communication equipment (user control);

(f) prevent the unauthorised processing of data in national RECAMAS, in iRCMS,

in RIAT and in the communication portal and any unauthorised modification or

erasure of data (control of data entry);

(g) ensure that persons authorised to access national RECAMAS, iRCMS, RIAT

and the communication portal have access only to the data covered by their

access authorisation, by means of individual and unique user IDs and

confidential access modes only (data access control);

(h) ensure that all authorities with a right of access to national RECAMAS,

iRCMS, RIAT and the communication portal create profiles describing the

EN 31 EN

functions and responsibilities of persons who are authorised to access, enter,

update, erase and search the data (personnel profiles);

(i) ensure that it is possible to verify and establish to which bodies personal data

may be transmitted using data communication equipment (communication

control);

(j) ensure that it is possible to verify and establish what data have been processed

in national RECAMAS, in iRCMS, in RIAT and in the communication portal,

when, by whom and for what purpose (control of data recording);

(k) prevent the unauthorised reading, copying, modification or deletion of personal

data during the transmission of personal data to or from national RECAMAS,

iRCMS, RIAT and the communication portal, or during the transport of data

media, in particular by means of appropriate encryption techniques (transport

control);

(l) ensure that installed systems may, in the event of interruption, be restored

(recovery);

(m) ensure that national RECAMAS, iRCMS, RIAT and the communication portal

perform its functions, that the appearance of faults in the functions is reported

(reliability) and that stored personal data cannot be corrupted by means of the

system malfunctioning (integrity);

(n) monitor the effectiveness of the security measures referred to in this paragraph

and take the necessary organisational measures related to internal monitoring in

order to ensure compliance with this Regulation (self-auditing) and to

automatically detect within 24 hours any relevant events arising from the

application of measures listed in points (b) to (k) that might indicate the

occurrence of a security incident.

2. Frontex, eu-LISA and Member States shall cooperate within the

Program Management Board and the Advisory Group in order to ensure a coherent

data security approach based on a security risk management process.

Article 19

Keeping of logs

1. All data processing operations in national RECAMAS, in iRCMS, in RIAT and in

the communication portal shall be logged for the purposes of checking whether those

processing operations are carried out lawfully, ensure the proper functioning of those

systems, self-monitoring as well as ensure data integrity and security.

2. The log shall show:

(a) the purpose of the processing operation;

(b) the data processed;

(c) the date and time of the processing operation;

(d) the name of the entity and of the person responsible that processed the data.

3. The logs shall only be used for the purposes referred to in paragraph 1 and shall be

deleted three years after their creation.

EN 32 EN

4. Logs may be kept longer than the periods referred to in paragraph 3 if they are

required for monitoring and/or oversight procedures that are already ongoing.

5. Each competent authority shall have access to the logs relating to the data it

recorded.

6. For the purposes of self-monitoring and ensuring the proper functioning, data

integrity and data security of iRCMS and RIAT, Frontex shall have access to the

corresponding logs.

7. For the purposes of self-monitoring and ensuring the proper functioning, data

integrity and data security of the communication portal, eu-LISA shall have access to

the corresponding logs.

8. National data protection supervisory authorities and the European Data Protection

Supervisor shall have access to the logs on request, to the extent necessary to fulfil

their tasks.

Article 20

Retention period for data storage

1. Where a return has been confirmed in accordance with Article 6 of Regulation (EU)

2018/1860, the data recorded in national RECAMAS, in iRCMS and in RIAT shall

be stored for 10 years from the date of the confirmation of return. When a return

decision is annulled or withdrawn, the corresponding data shall be deleted

immediately.

2. Where a return decision is accompanied by an entry ban in accordance with Article

8 of Regulation (EU) 2026/2280, the data recorded in national RECAMAS, in

iRCMS and in RIAT shall be stored for as long as that entry ban is in force or for the

period referred to in paragraph 1, whichever is longer.

3. Upon expiry of the data storage period referred to in paragraph 1 and paragraph 2,

the data shall be automatically erased from national RECAMAS, iRCMS and RIAT.

4. This Article shall not affect the specific rules applicable to Frontex in accordance

with Article [110] of Regulation (EU) …/… [EBCG Regulation].

Article 21

Rights of data subjects

Data subjects may address requests to exercise their rights under applicable data protection

rules to Frontex, which shall transmit the request via the communication portal to the

competent controller, in accordance with Article 23.

Article 22

Statistics

1. The anonymised data referred to in Article 46 of Regulation (EU) 2026/2280 and in

Article 7 of Regulation (EC) No 862/2007, as well as anonymised data on

cases status, shall be recorded, from national RECAMAS, iRCMS and RIAT, in the

CRRS in an automated manner.

2. The statistics generated by the CRRS shall be accessible to competent authorities,

Frontex, eu-LISA and the Commission.

EN 33 EN

3. The Commission may adopt implementing acts specifying the technical requirements

necessary for the recording in the CRRS, as well as the specific types of data needed

for the recording of data on cases status. Those implementing acts shall be adopted in

accordance with the examination procedure referred to in Article 34(2).

Article 23

Responsibility for personal data processing

1. For national RECAMAS, each Member State shall designate the authority which is

to be considered as controller in accordance with Article 4, point (7), of Regulation

(EU) 2016/679 in relation to the processing of data it records in this system and for

its operational management. Frontex shall be considered as processor in accordance

with Article 3, point (12), of Regulation (EU) 2018/1725 in relation to the processing

of data it records in this system.

2. For iRCMS, the authority designated in compliance with paragraph 1 in each

Member State shall be considered as controller in accordance with Article 4, point

(7), of Regulation (EU) 2016/679 in relation to the processing of data it records in

this system. Frontex shall be considered as processor in accordance with Article 3,

point (12), of Regulation (EU) 2018/1725 in relation to the processing of data it

records in iRCMS and for its operational management.

3. For RIAT, the authority designated in compliance with paragraph 1 in each Member

State shall be considered as controller in accordance with Article 4, point (7), of

Regulation (EU) 2016/679 in relation to the processing of data it records in this

system on cases from national reintegration assistance programs. The authorities

designated by Member States and Frontex shall be considered as joint controllers in

accordance with Article 26 of Regulation (EU) 2016/679 and Article 28 of

Regulation (EU) 2018/1725, respectively, in relation to the processing of personal

data recorded in RIAT for cases managed under an EU reintegration assistance

program. The responsibilities of each joint controller shall be limited to the data it

records in RIAT. Frontex shall be considered as processor in accordance with Article

3, point (12), of Regulation (EU) 2018/1725 in relation to the processing of data it

records on cases from national reintegration assistance programs managed in RIAT

and for the operational management of RIAT.

4. For the communication portal, the authorities designated by Member States in

compliance with paragraph 1 and Frontex shall be considered as joint controllers in

accordance with Article 26 of Regulation (EU) 2016/679 and Article 28 of

Regulation (EU) 2018/1725, respectively, in relation to the processing of personal

data exchanged through the communication portal. The responsibilities of each joint

controller shall be limited to the data it processes in the communication portal. eu-

LISA shall be considered as processor in accordance with Article 3, point (12), of

Regulation (EU) 2018/1725 in relation to the operational management of the

communication portal.

Article 24

Staff training

1. Before being authorised to process data stored in national RECAMAS, in iRCMS, in

RIAT and in the communication portal and periodically after access to national

RECAMAS, iRCMS, RIAT and the communication portal has been granted, the staff

EN 34 EN

of competent authorities and Frontex having a right to access national RECAMAS,

iRCMS, RIAT and the communication portal shall receive appropriate training

courses on data security, fundamental rights including data protection, and the rules

and procedures for data processing, including measures for improving the data

quality. The staff shall be informed of any relevant provisions on criminal offences

and penalties, including those provided in Article 26.

2. Member States shall provide training courses to their staff on national RECAMAS.

3. Frontex shall provide training courses to its staff and to competent authorities on

Frontex RECAMAS, iRCMS and RIAT.

4. eu-LISA shall provide training courses to competent authorities on the technical

functioning of the communication portal.

Article 25

Cooperation between national data protection supervisory authorities and the European

Data Protection Supervisor

In accordance with Article 62 of Regulation (EU) 2018/1725, the national supervisory

authorities and the European Data Protection Supervisor shall, each acting within the scope of

their respective competences, cooperate actively in the framework of their responsibilities and

ensure, in particular, the coordinated supervision of the communication portal.

Article 26

Penalties

Member States shall lay down the rules on penalties applicable to infringements of this

Regulation and shall take all measures necessary to ensure that they are implemented. The

penalties provided for shall be effective, proportionate and dissuasive. Member States shall,

without delay, notify the Commission of those rules and of those measures and shall notify it,

without delay, of any subsequent amendment affecting them.

Chapter 4

AMENDMENTS TO OTHER UNION LEGAL ACTS

Article 27

Amendments to Regulation (EU) 2018/1726

Regulation (EU) 2018/1726 is amended as follows:

(1) in Article 1, the following paragraphs 4c and 4d are inserted:

'4c. The Agency shall be responsible for the development, including the design, operational

management and technical evolutions, of a secure communication channel between migration

authorities ('the communication portal'), in accordance with Regulation (EU) …/… of the

European Parliament and of the Council(23) [this Regulation].

4d. The Agency shall be responsible for supporting:

(23) Regulation (EU) …/… of the European Parliament and of the Council [full title of this Regulation].

EN 35 EN

(a) the European Border and Coast Guard Agency in the development, including technical

evolutions, of a reference implementation of a return case management system ('Frontex

RECAMAS'), in accordance with Regulation (EU) …/… [this Regulation];

(b) the European Border and Coast Guard Agency in the development, including technical

evolutions, of an integrated Union readmission case management system ('iRCMS') and a

Union reintegration case management system ('RIAT'), in accordance with Regulation (EU)

…/… [this Regulation].';

(2) the following Articles 8e and 8f are inserted:

'Article 8e

Tasks related to the communication portal

In relation to the communication portal, the Agency shall perform:

(a) the tasks conferred on it by Article 15(4) and Article 17(4) of Regulation (EU) …/… [this

Regulation];

(b) tasks relating to training on the technical use of the communication portal, including the

provision of training materials.

Article 8f

Tasks related to Frontex RECAMAS, iRCMS and RIAT

In relation to the Frontex RECAMAS, iRCMS and RIAT, the Agency shall perform the tasks

conferred on it by Regulation (EU) …/… [this Regulation].';

(3) in Article 14, paragraph 1 is replaced by the following:

'1. The Agency shall monitor developments in research relevant for the operational

management of SIS, VIS, Eurodac, the EES, ETIAS, DubliNet, ECRIS-TCN, the e-CODEX

system, the JITs collaboration platform, the communication portal and other large-scale IT

systems as referred to in Article 1(5).';

(4) in Article 19(1), first subparagraph, the following point (qq) is added:

'(qq) adopt the reports on the development and activities of the communication portal

pursuant to Article 37(2) of Regulation (EU) …/… [this Regulation].'.

Article 28

Amendments to Regulation (EU) 2018/1860

In Regulation (EU) 2018/1860, the following Article 17a is inserted:

'Article 17a

Keeping of data contained in alerts on return in national case management systems for

the purposes of Regulation (EU) …/… of the European Parliament and of the Council

[this Regulation]

1. By way of derogation from Article 41(2) of Regulation (EU) 2018/1861, following a hit on

an alert on return entered by another Member State pursuant to Article 3, the competent

authority of the executing Member State may keep in their national RECAMAS established

pursuant to Regulation (EU) …/… of the European Parliament and of the Council(24)[this

(24) Regulation (EU) …/… of the European Parliament and of the Council [full title of this Regulation].

EN 36 EN

Regulation] the data contained in that alert to the extent necessary for the purposes referred to

in Article 7(1) of Regulation (EU) …/… [this Regulation].

2. Where the alert has been modified by the issuing Member State in accordance with Article

44(2) of Regulation (EU) 2018/1861, the executing Member State shall update those data in

its national RECAMAS established pursuant to Regulation (EU) …/… [this Regulation]

accordingly.

3. By way of derogation from Article 42(1) of Regulation (EU) 2018/1861, the data kept

pursuant to paragraph 1 shall be stored and erased in accordance with Article 20(1) to (3) of

Regulation (EU) …/… [this Regulation].

4. Article 15 shall apply to transfers or the making available of the data kept pursuant to

paragraph 1.'.

Article 29

Amendments to Regulation (EU) 2019/817

In Regulation (EU) 2019/817, the following Article 48a is added:

'Article 48a

Communication portal

1. The communication between the Member States’ authorities and between those authorities

with the ETIAS Central Unit required under this Regulation shall be carried out through the

communication portal established under Regulation (EU) …/… of the European Parliament

and of the Council(25) [this Regulation] for the following purposes:

(a) the exercise of data protection rights pursuant to Article 48(3) and (4);

(b) informing the competent authority about the rectification or erasure of a link pursuant to

Article 31(3) and Article 33(5);

(c) informing about the rectification or erasure of a link pursuant to Article 32(7);

(d) informing the competent authority about a link incorrectly recorded pursuant to Article

32(7).

2. The Commission is empowered to adopt implementing acts to specify the formats for

communications under this Regulation via the communication portal. Those implementing

acts shall be adopted in accordance with the examination procedure referred to in Article

74(2).'.

Article 30

Amendments to Regulation (EU) 2019/818

Regulation (EU) 2019/818 is amended as follows:

(1) Article 39 is amended as follows:

(a) paragraphs 1 and 2 are replaced by the following:

'1. A central repository for reporting and statistics (CRRS) is established for the purpose of

supporting the objectives of the SIS, Eurodac and ECRIS-TCN, in accordance with the

respective legal instruments governing those systems, and to provide cross-system statistical

(25) Regulation (EU) …/… of the European Parliament and of the Council [full title of this Regulation].

EN 37 EN

data and analytical reporting for policy, operational and data quality purposes. The CRRS

shall also support the objectives of Regulation (EU) 2024/982 of the European Parliament and

of the Council(26), Regulation (EU) 2025/13 of the European Parliament and of the

Council(27) and of Regulation (EU) …/… of the European Parliament and of the

Council(28) [this Regulation].

2. eu-LISA shall establish, implement and host in its technical sites the CRRS containing the

data and statistics referred to in Article 12 of Regulation (EU) 2024/1358, Article 74 of

Regulation (EU) 2018/1862 and Article 32 of Regulation (EU) 2019/816 logically separated

by EU information system. eu-LISA shall collect the data and statistics from the router

referred to in Article 71(2) of Regulation (EU) 2024/982 and in Article 39(1) of Regulation

(EU) 2025/13. eu-LISA shall collect the data and statistics referred to in Article 22 of

Regulation (EU) …/… [this Regulation]. Access to the CRRS shall be granted by means of

controlled, secured access and specific user profiles, solely for the purposes of reporting and

statistics, to the authorities referred to in Article 12 of Regulation (EU) 2024/1358, Article 74

of Regulation (EU) 2018/1862, Article 32 of Regulation (EU) 2019/816, Article 71(2) of

Regulation (EU) 2024/982, Article 13(1) of Regulation (EU) 2025/13 and Article 22(2) of

Regulation (EU) …/… [this Regulation].';

(b) in paragraph 4, the following point (d) is added:

'(d) a secure communication infrastructure to connect the CRRS to national return case

management systems ('national RECAMAS'), the integrated Union readmission case

management system ('iRCMS') and the Union reintegration case management system

('RIAT'), in compliance with Regulation (EU) …/… [this Regulation].';

(2) the following Article 48a is inserted:

'Article 48a

Communication portal

1. The communication between the Member States’ authorities and between those authorities

with the ETIAS Central Unit required under this Regulation shall be carried out through the

communication portal established under Regulation (EU) …/… [this Regulation] for the

following purposes:

(a) the exercise of data protection rights pursuant to Article 48(3) and (4);

(b) informing the competent authority about the rectification or erasure of a link pursuant to

Article 31(3) and Article 33(5);

(c) informing about the rectification or erasure of a link pursuant to Article 32(7);

(d) informing the competent authority about a link incorrectly recorded pursuant to Article

32(7).

(26) Regulation (EU) 2024/982 of the European Parliament and of the Council of 13 March 2024 on the

automated search and exchange of data for police cooperation, and amending Council Decisions

2008/615/JHA and 2008/616/JHA and Regulations (EU) 2018/1726, (EU) No 2019/817 and (EU)

2019/818 of the European Parliament and of the Council (the Prüm II Regulation) (OJ L, 2024/982,

5.4.2024, ELI: http://data.europa.eu/eli/reg/2024/982/oj). (27) Regulation (EU) 2025/13 of the European Parliament and of the Council of 19 December 2024 on the

collection and transfer of advance passenger information for the prevention, detection, investigation and

prosecution of terrorist offences and serious crime, and amending Regulation (EU) 2019/818 (OJ L,

2025/13, 8.1.2025, ELI: http://data.europa.eu/eli/reg/2025/13/oj). (28) Regulation (EU) …/… of the European Parliament and of the Council [full title of this Regulation].

EN 38 EN

2. The Commission is empowered to adopt implementing acts to specify the formats for

communications under this Regulation via the communication portal. Those implementing

acts shall be adopted in accordance with the examination procedure referred to in Article

70(2).';

(3) Article 62 is amended as follows:

(a) the following paragraph 3a is inserted:

'3a. The duly authorised staff of the competent authorities of Member States, the European

Border and Coast Guard Agency, eu-LISA and the Commission shall have access to consult

the data related to national RECAMAS, iRCMS and RIAT referred to in Article 22 of

Regulation (EU) …/… [this Regulation].';

(b) paragraph 6 is replaced by the following:

'6. For the purpose of paragraphs 1, 2, 3 and 3a, eu-LISA shall store the data referred to in

those paragraphs in the CRRS. It shall not be possible to identify individuals from the data

included in the CRRS, but the data shall allow the authorities listed in paragraphs 1, 2, 3 and

3a to obtain customisable reports and statistics to enhance the efficiency of border checks, to

help authorities processing visa applications and to support evidence-based policy-making on

migration and security in the Union.'.

Chapter 5

FINAL PROVISIONS

Article 31

Costs

The costs incurred in connection with the development, including technical evolutions, and

operational management of national RECAMAS shall be borne by each Member State

concerned. These costs shall include the costs incurred in connection with the integration of

Frontex RECAMAS, iRCMS, RIAT and the communication portal into national RECAMAS,

as well as with the customisation of the Frontex RECAMAS.

Article 32

Notifications

1. Member States shall notify the Commission, Frontex and eu-LISA of the authority

which is to be considered as controller and joint controller in accordance with Article

23.

2. Member States shall notify the Commission, Frontex and eu-LISA of the competent

authorities referred to in Article 7, Article 8 and Article 9, which may record,

consult, rectify or erase data.

3. Member States shall notify the Commission, Frontex and eu-LISA of their single

point of contact referred to in Article 14(3).

4. Frontex shall maintain a continuously updated public website containing the

information referred to in this Article.

Article 33

Start of operations

EN 39 EN

1. By [OJ: please fill in: four years after the date of entry into force of this Regulation]

at the latest, Member States shall have in place and use a national RECAMAS. Each

Member State shall notify, without delay, the Commission and Frontex of the date on

which it started using its national RECAMAS.

2. The Commission shall determine, by means of an implementing act, the date of

completion of the development of iRCMS and RIAT, once Frontex has declared the

successful completion of a comprehensive test of iRCMS and RIAT, to be conducted

with the support of eu-LISA.

3. Within one year from the date determined in accordance with paragraph 2 or, where

later, from the date of notification referred to in paragraph 1, each Member State

shall take the necessary measures to integrate iRCMS and RIAT into its national

RECAMAS, in accordance with Article 15(3) and shall notify the Commission and

Frontex of the successful integration.

4. The Commission shall determine, by means of an implementing act, the date from

which iRCMS and RIAT are to start operations in the Member States concerned and

are operated by Frontex, once Frontex has declared, for the Member States

concerned, the successful integration of iRCMS and RIAT in the national

RECAMAS of the Member States concerned. Frontex’ declaration shall be based on

the successful completion of comprehensive tests and conducted, upon receipt of the

notification referred to in paragraph 3, in cooperation with the Member State or

Member States concerned and with the support of eu-LISA.

5. The Commission shall determine, by means of an implementing act, the date of

completion of the development of the communication portal, once eu-LISA has

declared the successful completion of a comprehensive test of the communication

portal, to be conducted in cooperation, where necessary, with Frontex and the

Member States.

6. Within one year from the date determined in accordance with paragraph 5, or, where

later, from the date of notification referred to in paragraph 1, each Member State

shall take the necessary measures to integrate the communication portal into its

national RECAMAS, in accordance with Article 15(4) and shall notify the

Commission and Frontex of the successful integration. Within one year from the date

determined in accordance with paragraph 5, Frontex shall take the necessary

measures to integrate the communication portal into IRMA in accordance with

Article 14(2) and shall notify the Commission of the successful integration.

7. The Commission shall determine, by means of an implementing act, the date from

which the communication portal is to start operations in the Member States

concerned and is operated by Frontex, once eu-LISA has declared, for the Member

States concerned, the successful integration of the communication portal in the

national RECAMAS of the Member States concerned and in IRMA. eu-LISA’s

declaration shall be based on the successful completion of comprehensive tests and

conducted, upon receipt of the notification referred to in paragraph 6, in cooperation

with the Member States concerned.

8. The Commission shall inform the European Parliament and the Council of the dates

determined in accordance with paragraphs 2, 4, 5 and 7.

9. The implementing acts referred to in paragraphs 2, 4, 5 and 7 shall be published in

the Official Journal of the European Union.

EN 40 EN

10. Member States and, where applicable, Frontex, shall start using iRCMS, RIAT and

the communication portal from the dates determined in accordance with paragraph 4

and paragraph 7 respectively.

Article 34

Committee procedure

1. The Commission shall be assisted by a committee. That committee shall be a

committee within the meaning of Regulation (EU) No 182/2011.

2. Where reference is made to this paragraph, Article 5 of Regulation (EU) No

182/2011 shall apply.

Article 35

Advisory Group

1. An Advisory Group shall be established by Frontex.

2. The Advisory Group provides Frontex and eu-LISA with the expertise related to the

RECAMAS Model, Frontex RECAMAS, national RECAMAS, iRCMS, RIAT and

the communication portal, in particular in the context of the preparation of their

annual work programmes and their annual activity reports.

3. The Advisory Group shall be composed of national experts, two project managers

from Frontex, two project managers from eu-LISA and one member from the

Commission. It shall be chaired by Frontex.

Article 36

Contact point

Each Member State shall designate an authority as the contact point for the implementation of

this Regulation. Each Member State shall communicate the name of that authority to the

Commission. If a Member State changes its designated authority, it shall inform the

Commission accordingly.

Article 37

Monitoring and evaluation

1. Frontex shall submit to the European Parliament, to the Council, to the Commission

and to the European Data Protection Supervisor an annual report on the development

and activities of Frontex RECAMAS, national RECAMAS, iRCMS and RIAT,

including on their technical functioning and security. The annual report shall include

information on the operational management, including data protection and security

incidents, and performance of these systems against pre-defined quantitative

indicators for the objectives relating to output, cost-effectiveness and quality of

service.

2. eu-LISA shall submit to the European Parliament, to the Council, to the Commission

and to the European Data Protection Supervisor an annual report on the development

and activities of the communication portal, including on its technical functioning and

security. The annual report shall include information on the management and

EN 41 EN

performance of this system against pre-defined quantitative indicators for the

objectives relating to output, cost-effectiveness and quality of service.

3. Five years after the start of operations of all national RECAMAS, iRCMS, RIAT and

the communication portal and every five years thereafter, the Commission shall

submit to the European Parliament and to the Council an evaluation report on the

application of this Regulation. For this purpose, the Commission shall have

permanent access to Frontex RECAMAS, iRCMS, RIAT and the communication

portal without the possibility to access any personal data.

4. Member States shall provide Frontex, eu-LISA and the Commission with the

information necessary to prepare the annual reports and the evaluation referred to in

this Article.

5. Evaluations may be conducted in accordance with Council Regulation (EU)

2022/922(29).

Article 38

Entry into force

This Regulation shall enter into force on the twentieth day following that of its publication in

the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels,

For the European Parliament For the Council

The President The President

[...] [...]

(29) Council Regulation (EU) 2022/922 of 9 June 2022 on the establishment and operation of an evaluation

and monitoring mechanism to verify the application of the Schengen acquis, and repealing Regulation

(EU) No 1053/2013 (OJ L 160, 15.6.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/922/oj).

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ................. 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 3

1.3.4. Indicators of performance ............................................................................................ 4

1.4. The proposal/initiative relates to: ................................................................................. 4

1.5. Grounds for the proposal/initiative .............................................................................. 5

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 5

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 5

1.5.3. Lessons learned from similar experiences in the past .................................................. 6

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 7

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 7

1.6. Duration of the proposal/initiative and of its financial impact .................................... 8

1.7. Method(s) of budget implementation planned ............................................................. 8

2. MANAGEMENT MEASURES................................................................................. 10

2.1. Monitoring and reporting rules .................................................................................. 10

2.2. Management and control system(s) ........................................................................... 10

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed ................ 10

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them.......................................................................................................... 11

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ......................................... 11

2.3. Measures to prevent fraud and irregularities .............................................................. 12

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 13

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 13

EN 2 EN

3.2. Estimated financial impact of the proposal on appropriations ................................... 15

3.2.1. Summary of estimated impact on operational appropriations.................................... 15

3.2.1.1. Appropriations from voted budget ............................................................................. 15

3.2.2. Summary of estimated impact on administrative appropriations ............................... 20

3.2.2.1. Appropriations from voted budget .............................................................................. 20

3.2.3. Estimated requirements of human resources.............................................................. 20

3.2.3.1. Financed from voted budget....................................................................................... 20

3.2.4. Overview of estimated impact on digital technology-related investments ................ 22

3.2.5. Compatibility with the current multiannual financial framework.............................. 22

3.2.6. Third-party contributions ........................................................................................... 23

3.2.7. Estimated human resources and the use of appropriations required in a decentralised

agency ........................................................................................................................ 23

3.3. Estimated impact on revenue ..................................................................................... 26

4. DIGITAL DIMENSIONS .......................................................................................... 27

4.1. Requirements of digital relevance .............................................................................. 27

4.2. Data ............................................................................................................................ 30

4.3. Digital solutions ......................................................................................................... 33

4.4. Interoperability assessment ........................................................................................ 41

4.5. Measures to support digital implementation .............................................................. 45

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal 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

1.2. Policy area concerned

Home Affairs

1.3. Objective(s)

1.3.1. General objectives

Support the implementation of the rules on return, readmission and reintegration 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.

1.3.2. Specific objectives

Specific objective 1: increase data sharing between competent authorities within the

same Member State, between Member States and between member States and

Frontex, and between member States or Frontex and third countries, in compliance

with data protection rules, to ensure that the information necessary to carry out and

monitor return, readmission and reintegration processes is available.

Specific objective 2: foster the digitalisation of return, readmission and reintegration

processes and remedy the limited functionalities of existing IT systems to ensure that

processes and reporting requirements are more digitalised, user-friendly, and

automated, and to significantly decrease the administrative burden and workload of

national authorities.

Specific objective 3: 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.

1.3.3. Expected results and impact

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, an application allowing the communication between third

country nationals and migration authorities) that may be integrated into national

RECAMAS. Frontex will develop and maintain an EU integrated case management

system on readmission (iRCMS) and on reintegration (RIAT), in cooperation with

eu-LISA, to be integrated in national RECAMAS.

EN 4 EN

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.

By digitalising the case management of return, readmission and reintegration

procedures, the initiative will speed up, simplify and streamline processes, increase

their transparency and decrease the workload for national competent authorities and

Frontex.

1.3.4. Indicators of performance

Specific objective 1

– Number of datasets on return, readmission and reintegration cases requested by

Member States and made available to other Member States within the

applicable time limits laid down by the Return Regulation.

– Number of readmission requests processed via iRCMS.

Specific objective 2

– Number of national RECAMAS in place.

– Number of Member States making use of the Frontex RECAMAS, or parts of

it.

– Number of national RECAMAS having integrated iRCMS and RIAT.

– Number of national RECAMAS connected to ESP, CRRS and SIS.

– Number of national RECAMAS connected to the communication portal.

– Number of sub-processes streamlined or automated.

– Average duration of the processing time per return, readmission and

reintegration case.

– Number of staff trained in new procedures and IT systems.

Specific objective 3

– Number of statistical datasets (as per the Return Regulation) created

automatically.

– Number of statistical datasets (as per the Return regulation) provided within

the applicable time limits laid down by the Return Regulation.

1.4. The proposal/initiative relates to:

☑a new action

a new action following a pilot project / preparatory action1

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

1 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 5 EN

1.5. Grounds for the proposal/initiative

1.5.1. Requirements to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

All systems (national RECAMAS, Frontex RECAMAS, iRCMS, RIAT and the

communication portal) are meant to be developed within four years as of the entry

into force of the regulation, in line with the following indicative timeline:

- Q3 2028: entry into force of the regulation.

- Q3/Q4 2028: establishment of the governance framework for the development

of the IT systems.

- Q3 2028-Q1 2030: inception phase, including recruitment.

- Q1 2030-Q2 2030: procurement phase.

- Q2 2030-Q1 2032: development phase.

- Q1 2032-Q2/ 2032: testing phase.

- Q2 2032-Q3 2032: gradual onboarding phase and gradual start of operations.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante)

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. Inefficient digital management of return, readmission and reintegration

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.

Expected generated EU added value (ex-post)

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 return, readmission and

reintegration 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

EN 6 EN

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.

1.5.3. Lessons learned from similar experiences in the past

On return, 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’). 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, 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.

On readmission, 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 Readmission Case Management

Systems, 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.

On reintegration, 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’), which was established in 2008. In addition to communication,

EN 7 EN

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.

The availability, the use and functionalities of existing IT systems vary greatly

between Member States. The existing IT systems for return, readmission and

reintegration 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.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

Digitalisation is explicitly identified in the Pact on Asylum and Migration as an

enabler for swift and efficient migration procedures. Digital systems are essential to

improve operational cooperation, ensure reliable data collection, reduce

administrative burden, and strengthen the monitoring and enforcement of EU

migration rules. This objective aligns with the broader EU political ambition to

develop European digital solutions that simplify procedures while safeguarding

fundamental rights and data protection.

The need for digitalisation of case management in the area of return, readmission and

reintegration has been underlined in the Political Guidelines of President von der

Leyen (2024-2029), the Commission Work Programmes for 2025 and 2026, which

explicitly present the initiative as having a strong simplification dimension (3), and

the European Asylum and Migration Management Strategy (4). The Return

Regulation establishes a common EU return system allowing for the enhanced

sharing and transfer of data, in compliance with data protection rules.

The investment required at the EU level and Member States’ level may fall within

the amounts negotiated for the MFF 2028-2034.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The initiative implies the creation of new IT systems, which will be entrusted to

Frontex and eu-LISA.

Frontex will develop and maintain an IT reference implementation for return case

management (Frontex RECAMAS), the EU Integrated Readmission Case

Management System (iRCMS), the EU Reintegration Case Management System

(RIAT).

eu-LISA will design, develop and maintain a communication channel between

migration authorities (communication portal).

Achieving these objectives requires broadening the mandate of Frontex and eu-LISA,

as these new tasks are not covered by the existing ones. New financial and human

resources are therefore necessary to enable both agencies to fulfil their new tasks.

A Program Management Board and an Advisory Group will support the development

and further evolutions of the new IT systems. DG HOME will be part of these two

EN 8 EN

structures. Meetings will take place on a regular basis and at least six times per year

in the development phase. More generally, DG HOME will have to monitor the

development, implementation and overall compliance with the future regulation.

Accordingly, new staff is required to allow the Commission to fulfil its new tasks.

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

–  in effect from [DD/MM]YYYY to [DD/MM]YYYY

–  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

☑unlimited duration

– Implementation with a start-up period from 2028 to 2034,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned2

Direct management by the Commission

–  by its departments, including by its staff in the Union delegations;

–  by the executive agencies

Shared management with the Member States

☑Indirect management by entrusting budget implementation tasks to:

–  third countries or the bodies they have designated

–  international organisations and their agencies (to be specified)

–  the European Investment Bank and the European Investment Fund

– ☑ bodies referred to in Articles 70 and 71 of the Financial Regulation

–  public law bodies

–  bodies governed by private law with a public service mission to the extent that

they are provided with adequate financial guarantees

–  bodies governed by the private law of a Member State that are entrusted with

the implementation of a public-private partnership and that are provided with

adequate financial guarantees

–  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on

European Union, and identified in the relevant basic act

– bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance with

sector-specific rules, with the implementation of Union funds or budgetary

guarantees, to the extent that such bodies are controlled by public law bodies or

by bodies governed by private law with a public service mission, and are provided

2 Details of budget implementation methods and references to the Financial Regulation may be found on

the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 9 EN

with adequate financial guarantees in the form of joint and several liability by the

controlling bodies or equivalent financial guarantees and which may be, for each

action, limited to the maximum amount of the Union support.

Comments

For indirect management – implementation via two decentralized agencies (Frontex, eu-

LISA)

EN 10 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

The Commission will ensure that the necessary arrangements are in place to monitor

the functioning of the measures proposed and evaluate them against the main policy

objectives. Five years after the start of operations of all national RECAMAS,

iRCMS, RIAT and the communication portal, and every five years thereafter, the

Commission will submit an evaluation report to the European Parliament and the

Council assessing the implementation of the Regulation and its added value. The

report will also report on any direct or indirect impact on relevant fundamental

rights. It will examine results achieved against objectives and assess the continuing

validity of the underlying rationale and any implications for future options.

Frontex will submit an annual report to the European Parliament, to the Council, to

the Commission, and to the European Data Protection Supervisor on the

development and activities of Frontex RECAMAS, national RECAMAS, iRCMS

and RIAT, including on their technical functioning and security.

eu-LISA will submit an annual report to the European Parliament, to the Council, to

the Commission, and to the European Data Protection Supervisor on the

development and activities of the communication portal, including on its technical

functioning and security.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation methods, the funding implementation

mechanisms, the payment modalities and the control strategy proposed

Part of this proposal will be implemented via the European Border and Coast Guard

Agency and eu-LISA’s budgets, through indirect management.

Pursuant to the principle of sound financial management, the budgets of the

European Border and Coast Guard Agency and eu-LISA shall be implemented in

compliance with effective and efficient internal control. The European Border and

Coast Guard Agency and eu-LISA are therefore bound to implement an appropriate

control strategy coordinated among appropriate actors involved in the control chain.

Regarding ex-post controls, the European Border and Coast Guard Agency and eu-

LISA, as decentralised agencies, are notably subject to:

– internal audit by the Internal Audit Service of the Commission;

– annual reports by the European Court of Auditors, giving a statement of

assurance as to the reliability of the annual accounts and the legality and

regularity of the underlying transactions;

– annual discharge granted by the European Parliament;

– possible investigations conducted by OLAF to ensure, in particular, that the

resources allocated to agencies are put to proper use.

As partner DG to the European Border and Coast Guard Agency and eu-LISA, DG

HOME will implement its Control Strategy on decentralised agencies to ensure

reliable reporting in the framework of its Annual Activity Report (AAR). While

decentralised agencies have full responsibility for the implementation of their budget,

EN 11 EN

DG HOME is responsible for regular payment of annual contributions established by

the EU Budgetary Authorities.

Finally, the European Ombudsman provides a further layer of control and

accountability.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

For the budget implemented by the European Border and Coast Guard Agency and

eu-LISA, a specific Internal Control Framework based on the Internal Control

Framework of the European Commission is required. The Single Programming

Document must provide information on the internal control systems, while the

Consolidated Annual Activity Report (CAAR) must contain information on the

efficiency and effectiveness of the internal control systems, including as regards risk

assessment.

Moreover, the European Data Protection Supervisor and Frontex’s and eu-LISA’s

data protection officer (DPO) supervise Frontex’s and eu-LISA’s processing of

personal data.

Finally, as partner DG of the European Border and Coast Guard Agency and eu-

LISA, DG HOME runs an annual risk management exercise to identify and assess

potential high risks related to agencies’ operations. Risks considered as critical are

reported annually in DG HOME management plan and are accompanied by an action

plan stating the mitigating action.

At operational level the main risk identified is the lack of adequate levels of financial

and human resources to allow for the timely development of the new IT systems.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

For the European Border and Coast Guard Agency and eu-LISA, the ratio of ‘control

costs/value of the related funds managed’ is reported on by the Commission. The

2024 AAR of DG HOME reports 0,11% for this ratio in relation to Indirect

Management Entrusted Entities and Decentralised Agencies, including European

Border and Coast Guard Agency.

2.3. Measures to prevent fraud and irregularities

DG HOME will continue to apply its Anti-Fraud Strategy in line with the

Commission's Anti-Fraud Strategy (CAFS) in order to ensure inter alia that its

internal anti-fraud related controls are fully aligned with the CAFS and that its fraud

risk management approach is geared to identify fraud risk areas and adequate

responses.

For indirect management, the measures related to combating fraud, corruption and

any other illegal activities are outlined in specific provisions on combating fraud of

the European Border and Coast Guard Agency and eu-LISA’s founding regulations.

EN 12 EN

They require that, among other things, the two decentralised agencies adopt an anti-

fraud strategy.

Moreover, as partner DG, DG HOME has developed and implemented its own anti-

fraud strategy on the basis of the methodology provided by OLAF. Decentralised

agencies, including European Border and Coast Guard Agency, fall within the scope

of the strategy.

EN 13 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next Multiannual Financial

Framework. The source of financing and scope of Union financial commitment in the

post-2027 period remain subject to the outcome of interinstitutional negotiations on

the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

• Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure Contribution

Number

Diff./Non-

diff.3 from EFTA

countries4

from

candidate

countries and

potential

candidates5

From other third

countries6

other

assigned

revenue

1 [XX.YY.YY.YY]

(Frontex) Non-diff. NO NO YES YES

1 [XX.YY.YY.YY]

(eu-LISA) Diff. NO NO YES YES

• New budget lines requested

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure Contribution

Number

Diff./Non-

diff. from EFTA

countries

from

candidate

countries and

potential

candidates

from other

third countries

other assigned

revenue

[XX.YY.YY.YY]

Diff./Non

-diff. YES/NO YES/NO YES/NO YES/NO

[XX.YY.YY.YY]

Diff./Non

-diff. YES/NO YES/NO YES/NO YES/NO

[XX.YY.YY.YY] Diff./Non YES/NO YES/NO YES/NO YES/NO

3 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 4 EFTA: European Free Trade Association. 5 Candidate countries and, where applicable, potential candidates from the Western Balkans. 6 Frontex and eu-LISA receive contributions from the countries associated with the Schengen Agreement

(NO, IS, CH, LI).

EN 14 EN

-diff.

EN 15 EN

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

–  The proposal/initiative does not require the use of operational appropriations

– ☑ The proposal/initiative requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework 1 Economic, social and territorial cohesion, agriculture, rural and maritime

prosperity and security

EU contribution to a decentralised agency

EUR million (to three decimal places)

FRONTEX Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034 TOTAL MFF

2028-2034

Budget line: <…….> / EU Budget contribution to the agency 44,130 18,023 18,134 18,244 18,768 19,309 19,447 156,054

The amount of appropriations to be allocated to the agency in the next MFF is indicative and subject to the agreement on the MFF. It

should be integrated into the Agency’s subsidy due to the permanent nature of the tasks allocated by this proposal and will be

compensated, if relevant, by an equivalent reduction of a relevant programme envelope under the same MFF heading. If a compensatory

reduction is needed, the resources allocated to the Agency may also need to be revised through the annual budgetary procedure.

eu-LISA Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034 TOTAL MFF

2028-2034

Budget line: <…….> / EU Budget contribution to the agency 14,120 8,113 8,196 8,280 8,615 8,960 9,059 65,343

EN 16 EN

The amount of appropriations to be allocated to the agency in the next MFF is indicative and subject to the agreement on the MFF. It

should be integrated into the Agency’s subsidy due to the permanent nature of the tasks allocated by this proposal and will be

compensated, if relevant, by an equivalent reduction of a relevant programme envelope under the same MFF heading. If a compensatory

reduction is needed, the resources allocated to the Agency may also need to be revised through the annual budgetary procedure.

Year Year Year Year Year Year Year TOTAL MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

TOTAL operational

appropriations

(including contribution to

decentralised agency)

Commitments (4) 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

Payments (5) 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

TOTAL appropriations of an administrative nature

financed from the envelope for specific programmes (6) 0,000 0,000 0,000 0,000 0,000 0,000 0,000 0,000

TOTAL appropriations

under HEADING 1 Commitments =4+6 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

of the multiannual financial

framework Payments =5+6 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

Year Year Year Year Year Year Year TOTAL MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

TOTAL operational

appropriations (all

operational headings)

Commitments (4) 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

Payments (5) 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

TOTAL appropriations of an administrative

nature financed from the envelope for specific

programmes (all operational headings)

(6) 0,000 0,000 0,000 0,000 0,000 0,000 0,000 0,000

TOTAL appropriations

Under Heading 1 to 3 Commitments

=4+6 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

EN 17 EN

of the multiannual

financial framework

(Reference amount)

Payments =5+6 58,250 26,136 26,330 26,524 27,382 28,269 28,506 221,397

Heading of multiannual financial framework 4 ‘Administrative expenditure’7

DG HOME Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

 Human resources 0,388 0,388 0,388 0,388 0,388 0,388 0,388 2,716

 Other administrative expenditure 0,048 0,048 0,048 0,048 0,048 0,048 0,048 0,336

TOTAL DG

HOME Appropriations 0,436 0,436 0,436 0,436 0,436 0,436 0,436 3,052

TOTAL appropriations under HEADING 4 of

the multiannual financial framework

(Total

commitments =

Total

payments)

0,436 0,436 0,436 0,436 0,436 0,436 0,436 3,052

EUR million (to three decimal places)

Year Year Year Year Year Year Year TOTAL MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

TOTAL

appropriations under

HEADINGS 1 to 4

Commitments

58,68626,57226,76626,96027,81828,70528,942224,449

of the multiannual

financial framework Payments

58,68626,57226,76626,96027,81828,70528,942224,449

7 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 18 EN

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the

next Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the

annual budgetary procedure. All appropriations and staffing allocations as of 2028 are indicative.

EN 19 EN

3.2.2. Summary of estimated impact on administrative appropriations

–  The proposal/initiative does not require the use of appropriations of an

administrative nature

– ☑ The proposal/initiative requires the use of appropriations of an administrative

nature, as explained below

3.2.2.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year Year Year Year Year Year Year TOTAL

2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

Human resources 0,388 0,388 0,388 0,388 0,3880,3880,388 2,716

Other administrative expenditure 0,048 0,048 0,048 0,048 0,0480,0480,048 0,336

Subtotal HEADING 4 0,436 0,436 0,436 0,436 0,436 0,436 0,436 3,052

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Other expenditure of an administrative nature

0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL 0,436 0,436 0,436 0,436 0,436 0,436 0,436 3,052

The appropriations required for human resources and other expenditure of an administrative nature

will be met by appropriations from the DG that are already assigned to management of the action

and/or have been redeployed within the DG, together, if necessary, with any additional allocation

which may be granted to the managing DG under the annual allocation procedure and in the light of

budgetary constraints.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative

purposes only and does not pre-judge the next Multiannual Financial Framework. The source of

financing and scope of Union financial commitment in the post-2027 period remain subject to the

outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined

through the annual budgetary procedure. All appropriations and staffing allocations as of 2028 are

indicative.

3.2.3. Estimated requirements of human resources

–  The proposal/initiative does not require the use of human resources

– ☑ The proposal/initiative requires the use of human resources, as explained

below

3.2.3.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs)8

VOTED APPROPRIATIONS Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033 2034

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and

Commission’s Representation

Offices)

2 2 2 2 2 2 2

8 Please specify below the table how many FTEs within the number indicated are already assigned to the

management of the action and/or can be redeployed within your DG and what are your net needs.

EN 20 EN

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (in FTEs)

20 02 01 (AC, END from the ‘global envelope’)

0 0 0 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU Delegations)

0 0 0 0 0 0 0

Admin. Support

line

- at

Headquarters 0 0 0 0 0 0 0

[XX.01.YY.YY] - in EU

Delegations 0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) -

Heading 4 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 4

0 0 0 0 0 0 0

TOTAL 2222222

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative

purposes only and does not pre-judge the next Multiannual Financial Framework. The source of

financing and scope of Union financial commitment in the post-2027 period remain subject to the

outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined

through the annual budgetary procedure. All appropriations and staffing allocations as of 2028 are

indicative.

Considering the overall strained situation in Heading 4, in terms of both staffing and the level

of appropriations, the human resources required will be met by staff from the DG who are

already assigned to the management of the action and/or have been redeployed within the DG

or other Commission services.

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 4

or Research

To be financed

from BA line

To be financed

from fees

Establishment plan

posts

2 AD posts N/A

External staff (CA,

SNEs, INT)

Description of tasks to be carried out by:

EN 21 EN

Officials and temporary staff New tasks are foreseen for the Commission:

• To monitor the development, implementation and overall compliance

with the future regulation.

• To prepare and participate in the Program Management Board and

the Advisory Group that will support the development and further

evolutions of the new IT systems. Meetings will take place on a

regular basis and at least six times per year in the development phase

that will last several years.

External staff n/a

3.2.4. Overview of estimated impact on digital technology-related investments

NOT APPLICABLE

Compulsory: the best estimate of the digital technology-related investments entailed

by the proposal/initiative should be included in the table below.

Exceptionally, when required for the implementation of the proposal/initiative, the

appropriations under Heading 4 should be presented in the designated line.

The appropriations under Headings 1-3 should be reflected as “Policy IT expenditure

on operational programmes”. This expenditure refers to the operational budget to be

used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation

of the initiative and their associated investments (e.g. licences, studies, data storage).

The information provided in this table should be consistent with details presented

under Section 4 “Digital dimensions”.

TOTAL Digital

and IT

appropriations

Year Year Year Year Year Year Year TOTAL

MFF

2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

IT expenditure (corporate)

0 0 0 0 0 0 0 0

Subtotal

HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Policy IT expenditure on operational programmes

0 0 0 0 0 0 0 0

Subtotal outside

HEADING 4 0 0 0 0 0 0 0 0

TOTAL 0 0 0 0 0 0 0 0

3.2.5. Compatibility with the current multiannual financial framework

The proposal/initiative:

EN 22 EN

– ☑ can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF)

Frontex, eu-LISA – the source of financing and scope of Union financial

commitment in the post-2027 period remain subject to the outcome of

interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be

determined through the annual budgetary procedure

Admin lines – additional budget requested

–  requires use of the unallocated margin under the relevant heading of the MFF

and/or use of the special instruments as defined in the MFF Regulation

–  requires a revision of the MFF

3.2.6. Third-party contributions

The proposal/initiative:

– ☑ does not provide for co-financing by third parties

–  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year

Total 2028 2029 2030 2031 2032 2033 2034

Specify the co-

financing body

TOTAL

appropriations

co-financed

3.2.7. Estimated human resources and the use of appropriations required in a

decentralised agency

Staff requirements (full-time equivalent units)

Agency: FRONTEX Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Temporary agents

(AD Grades) 28 28 28 28 32 32 32

Temporary agents

(AST grades)

Temporary agents

(AD+AST) subtotal 28282828323232

Contract agents 9 9 9 9 10 10 10

Seconded national experts

Contract agents and

seconded national experts

subtotal

9 9 9 9101010

EN 23 EN

TOTAL staff 37 37 37 37 42 42 42

Agency: eu-LISA Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Temporary agents

(AD Grades) 15 15 15 15 17 17 17

Temporary agents

(AST grades)

Temporary agents

(AD+AST) subtotal 15 15 15 15 17 17 17

Contract agents 5 5 5 5 5 5 5

Seconded national experts

Contract agents and

seconded national experts

subtotal

5 5 5 5 5 5 5

TOTAL staff 20 20 20 20 22 22 22

Appropriations covered by the EU budget contribution in EUR million (to three decimal places)

Agency: FRONTEX Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL

2028 -

2034

Title 1: Staff expenditure 2,730 5,570 5,681 5,795 6,319 6,861 6,999 39,954

Title 2: Infrastructure and

operating expenditure 3,320 1,029 1,029 1,028 1,028 1,028 1,028 9.490

Title 3: Operational

expenditure 38,080 11,424 11,424 11,421 11,421 11,420 11,420 106,610

TOTAL of appropriations

covered by the EU budget 44,130 18,023 18,134 18,244 18,768 19,309 19,447 156,054

For 2028, recruitment is assumed to take place in July; therefore, only 50% of the average cost is taken

into account. The same approach is applied in 2032 to the additional staff. The staff costs are adjusted

with the current correction coefficient for Poland of 82,3% (Frontex) and 113.60% for Strasbourg (eu-

LISA).

Appropriations in EUR million (to three decimal places)

Agency: eu-LISA Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL

2028 -

2034

EN 24 EN

Title 1: Staff expenditure 2,030 4,141 4,224 4,308 4,643 4,989 5,088 29,423

Title 2: Infrastructure and

operating expenditure 3,000 0,922 0,922 0,922 0,922 0,921 0,921 8,530

Title 3: Operational

expenditure 9,090 3,050 3,050 3,050 3,050 3,050 3,050 27,390

TOTAL of appropriations

covered by the EU budget 14,120 8,113 8,196 8,280 8,615 8,960 9,059 65,343

Overview/summary of human resources and appropriations (in EUR million) required by the

proposal/initiative in a decentralised agency

Agency: FRONTEX Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL

2028 -

2034

Temporary agents (AD+AST) 28 28 28 28 32 32 32 -

Contract agents 9 9 9 9 10 10 10 -

Seconded national experts 0 0 0 0 0 0 0 -

Total staff 37 37 37 37 42 42 42 -

Appropriations covered by the

EU budget 44.130 18.023 18.134 18.244 18.768 19.309 19.447 156.054

Appropriations covered by fees

(if applicable) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Appropriations co-financed

(if applicable) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations 44,130 18,023 18,134 18,244 18,768 19,309 19,447 156,054

Agency: eu-LISA Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL

2028 -

2034

Temporary agents (AD+AST) 15 15 15 15 17 17 17 -

Contract agents 5 5 5 5 5 5 5 -

EN 25 EN

Seconded national experts 0 0 0 0 0 0 0 -

Total staff 20 20 20 20 22 22 22 -

Appropriations covered by the

EU budget 14,120 8,113 8,196 8,280 8,615 8,960 9,059 65,343

Appropriations covered by fees

(if applicable) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Appropriations co-financed

(if applicable) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations 14,120 8,113 8,196 8,280 8,615 8,960 9,059 65,343

3.3. Estimated impact on revenue

– ☑ The proposal/initiative has no financial impact on revenue.

–  The proposal/initiative has the following financial impact:

–  on own resources

–  on other revenue

–  please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

Budget revenue line:

Appropriations

available for

the current

financial year

Impact of the proposal/initiative9

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

n/a

Other remarks (e.g. method/formula used for calculating the impact on revenue or

any other information).

n/a

9 As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net

amounts, i.e. gross amounts after deduction of 20% for collection costs.

EN 26 EN

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

Reference to the

requirement

High-level

description of the

requirement

Stakeholders

affected by the

requirement

High-level

processes

Categories

Article 3, Article 27

(Technical

architecture)

Establishment of

three digital

systems to

manage cases

relating to return

(‘national

RECAMAS’),

readmission

(‘iRCMS’) and

reintegration

(‘RIAT’) of

third-country

nationals staying

illegally in the

Union, including

a communication

channel

connecting these

systems

(‘communication

portal’)

Member

States’s

competent

authorities

EU Agencies

(Frontex, eu-

LISA)

Third countries’

competent

authorities (for

iRCMS)

Third parties

competent for

reintegration

assistance (for

RIAT)

Establishment

of digital

systems

Digital solution

Digital public

service

Article 5 (EU

Information Systems)

Competent

authorities using

national

RECAMAS, the

iRCMS and

RIAT shall make

use of the ESP to

access EU

Information

Systems

Member

States’s

competent

authorities

Processing of

data

Digital Solution

Digital Public

Service

Article 6 (Connection

to other national

relevant IT systems)

Each national

RECAMAS shall

allow for the

connection with

other relevant

national IT

systems

Member

States’s

competent

authorities

Processing of

data

Digital Solution

Digital Public

Service

Articles 7 - 9 (Case

management

systems)

Article 7:

Recording of

data in national

Member

States’s

competent

Processing of

data

Digital Solution

Data

EN 27 EN

RECAMAS,

iRCMS and

RIAT

Article 8:

Consultation of

data recorded

Article 9:

Rectification and

erasure of data

recorded

authorities

Frontex

Digital Public

Service

Articles 10-14 (Case

management

systems)

Essential

functional

features:

(i) common to

national

RECAMAS,

iRCMS and

RIAT (Article

10)

(ii) of national

RECAMAS

(Article 11)

(iii) of iRCMS

(Article 12)

(iv) of RIAT

(Article 13)

(v) and of the

communication

portal (Article

14)

Member

States’s

competent

authorities

EU Agencies

(Frontex, eu-

LISA)

Processing of

data

Digital Solution

Digital Public

Service

Articles 15-17

(Development,

operation, and

responsibilities)

Organisational

measures

concerning the:

Development and

technical

evolutions

(Article 15)

Program

Management

Board (Article

16)

Operational

management

(Article 17)

Member

States’s

competent

authorities

EU Agencies

(Frontex, eu-

LISA)

Commission

Establishment

of digital

systems

Digital Public

Service

EN 28 EN

Article 18 (Data

security), Article 19

(Keeping of logs),

Article 20 (Retention

period for data

storage)

Measures to

ensure the

security of

iRCMS, RIAT,

and national

RECAMAS

Measures

regarding the

logging of all

data processing

operations, and

the retention

period for data

stored

Member

States’s

competent

authorities

EU Agencies

(Frontex, eu-

LISA)

Establishment

of digital

systems

Digital solution

Digital Public

Service

Article 22 (Statistics),

Article 29 and Article

30 (Amendments to

Regulations (EU)

2019/817 and

2019/818)

Automation of

statistics relating

to return,

readmission and

reintegration

Member

States’s

competent

authorities

eu-LISA

Processing of

data

Data

Digital Public

Service

Article 28

(Amendments to

Regulation (EU)

2018/1860)

Enabling the

possibility to

retain data

relevant for

return,

readmission and

reintegration

purposes from

the Schengen

Information

System into

national systems

Member

States’s

competent

authorities

eu-LISA

Processing of

data

Data

Digital Solution

Digital Public

Service

Article 32

(Notifications)

Data flows

pertaining to

notifications

Member

States’s

competent

authorities

EU Agencies

(Frontex, eu-

LISA)

Commission

Processing of

data

Data

Article 33 (Start of

operations)

Organisational

measures

pertaining to the

start of

operations for

Member

States’s

competent

authorities

EU Agencies

Establishment

of digital

systems

Digital Public

Service

EN 29 EN

national

RECAMAS,

iRCMS, RIAT

and the

communication

portal

(Frontex, eu-

LISA)

Commission

Article 36 (Contact

point)

Member States

shall

communicate the

name of the

designated

authority (or any

changes in said

designation) to

the Commission

Member

States’s

competent

authorities

Commission

Processing of

data

Data

Article 37

(Monitoring and

evaluation)

Data flows in the

context of the

monitoring and

evaluation of the

development and

activities of

Frontex

RECAMAS,

national

RECAMAS,

iRCMS and

RIAT, and

communication

portal

Member

States’s

competent

authorities

EU Agencies

(Frontex, eu-

LISA)

Commission

Processing of

data

Data

4.2. Data

Type of data Reference to the

requirement(s)

Standard and/or

specification (if applicable)

Data necessary for managing

cases in the area of return,

readmission and

reintegration

Article 7(1), itself referring

to Article 36(6) of the

Return Regulation

n/a

Statistical data in the area of

return, readmission and

reintegration

Article 22 n/a

Data from the Schengen

Information System relevant

for return, readmission and

Article 28 n/a

EN 30 EN

reintegration purposes

Data flows pertaining to

notifications

Article 32 n/a

Member States shall

communicate the name of

the designated authority (or

any changes in said

designation) to the

Commission

Article 36 n/a

Data flows in the context of

the monitoring and

evaluation of the

development and activities

of Frontex RECAMAS,

national RECAMAS,

iRCMS and RIAT, and

communication portal

Article 37 n/a

Alignment with the European Data Strategy

Due to the type of data processed and the fact that such data will be processed for very

specific purposes linked to return, readmission and reintegration, the proposed initiative is of

very limited relevance to the objective of achieving a genuine single market for data, which is

the underpinning objective of the European Data Strategy.

Alignment with the once-only principle

First, the proposed IT architecture will rely on the use of EU Information Systems (e.g. the

Schengen Information System, Eurodac, EES), which will be systematically queried via the

European Search Portal. Thanks to these EU Information systems and the interoperability

framework, the data is stored only once and its access by national competent authorities is

immediate.

Second, for the data that may not be available in EU Information Systems, the communication

portal will be used, ensuring a useful and necessary additional technical mean to share data,

without any redundancy with the EU Information Systems.

Third, one of the essential functional features to be complied with will be the automatic

retrieval of data between the three case management systems i.e. national RECAMAS (for

return), iRCMS (for readmission) and RIAT (for reintegration). This will ensure that

competent authorities are required to provide the same data only once, in compliance with the

once-only principle.

Data flows

EN 31 EN

Type of

data

References to

the

requirements

Stakeholder

who

provides the

data

Stakeholder

who

receives the

data

Trigger for

the data

exchange

Frequency

(if

applicable)

Data

necessary

for

managing

cases in the

area of

return,

readmission

and

reintegration

Article 7(1),

itself referring

to Article

36(6) of the

Return

Regulation

Member

States’

competent

authorities.

Frontex

(when

processing a

case upon

request from

a competent

authority)

Third

countries’

competent

authorities

(for part of

the

readmission

procedure).

Third parties

competent

for

reintegration

assistance

(for part of

the

reintegration

procedure)

Member

States’

competent

authorities

Frontex

(when

processing a

case upon

request from

a competent

authority)

Third

countries’

competent

authorities

(for part of

the

readmission

procedure).

Third parties

competent

for

reintegration

assistance

(for part of

the

reintegration

procedure)

Need to

manage

cases

relating to

return,

readmission

and

reintegration

n/a

Statistical

data in the

area of

return,

readmission

and

reintegration

Article 22Member

States’

competent

authorities

(to provide

the data to

the CRRS)

eu-LISA (to

produce the

statistics

through the

CRRS)

Member

States’

competent

authorities.

Frontex

eu-LISA.

Commission

Obligation to

comply with

reporting

requirements

Annually in

accordance

with Article

46 of the

Return

Regulation

and

quarterly

based on

Article 7 of

Regulation

(EC) No

862/2007

EN 32 EN

Data from

the

Schengen

Information

System and

relevant for

return,

readmission

and

reintegration

purposes

Article 28Member

States’

competent

authorities

Member

States’

competent

authorities

Need to

manage

cases

relating to

return,

readmission

and

reintegration

n/a

4.3. Digital solutions

Digital

solution

References

to the

requirement

s

Main

mandated

functionaliti

es

Responsi

ble body

How is

accessibi

lity

catered

for?

How is

reusability

considered?

Use of AI

technologi

es (if

applicable)

National

RECAMAS

Article 3

(Technical

architecture)

Article 6

(Connection

to other

national

relevant IT

systems)

Article 7

(Recording

of data in

national

RECAMAS,

in iRCMS

and in

RIAT)

Article 8

(Consultatio

n of data

recorded in

national

RECAMAS,

in iRCMS,

and in

RIAT)

To be based

on either

RECAMAS

Model,

Frontex

RECAMAS

or a

combination

of the two

Each

national

RECAMAS

shall allow

for the

connection

of other

national

relevant IT

systems and

for the

prompt,

secure, and

effective

transmission

of data from

and to those

systems

Member

States

n/a The use of

the

European

Search

Portal will

allow to

access the

information

stored in

EU

Information

Systems.

The system

should

ensure the

auto

matic

retrieval of

the

necessary

data

between

national

RECAMAS

, iRCMS

and RIAT

Where

relevant,

the

functionali

ties of the

system

should

make use

of artificial

intelligenc

e systems,

in

complianc

e with

Regulation

(EU)

2024/1689

.

EN 33 EN

Article 9

(Rectificatio

n and

erasure of

data

recorded in

national

RECAMAS,

in iRCMS

and in

RIAT)

Article 10

(Essential

functional

features

common to

national

RECAMAS,

iRCMS and

RIAT)

Article 11

(Essential

functional

features of

national

RECAMAS

)

Allow

competent

authorities

(and upon

agreement

by a

competent

authority,

Frontex) to

record data

Allow each

competent

authority of

origin to

consult the

data it

recorded.

Allow

Frontex,

upon

agreement

by the

competent

authority of

origin, to

consult the

data

Allow and

mandate

each

competent

authority of

origin and

Frontex to

rectify or

erase the

data

Establishing

essential

functional

features that

all three

case

managemen

t systems

should

comply with

(e.g.

issuance of

EN 34 EN

a single

identifier

allocated to

each third-

country

national for

whom a

case is

opened as

regards

return,

readmission

and, where

applicable,

reintegratio

n)

Establishing

essential

functional

features that

all national

RECAMAS

should

comply with

(e.g. support

to the

preparation,

issuance

and

notification

of return

decisions)

iRCMS Article 3

(Technical

architecture)

Article 10

(Essential

functional

features

common to

national

RECAMAS,

iRCMS and

RIAT)

Article 12

(Essential

functional

features of

Union

integrated

readmission

case

managemen

t system

Establishing

essential

functional

features that

all three

case

managemen

t systems

should

comply with

(e.g.

Frontex n/a The use of

the

European

Search

Portal will

allow to

access the

information

stored in

EU

Information

Systems.

The system

should

ensure the

auto

matic

Where

relevant,

the

functionali

ties of the

system

should

make use

of artificial

intelligenc

e systems,

in

complianc

e with

Regulation

(EU)

2024/1689

EN 35 EN

iRCMS) issuance of

a single

identifier

allocated to

each third-

country

national for

whom a

case is

opened as

regards

return,

readmission

and, where

applicable,

reintegratio

n)

Establishing

essential

functional

features that

iRCMS

should

comply with

(e.g.

possibility

to automate

the

initiation of

a

readmission

procedure

following

the issuance

of an

enforceable

return

decision)

retrieval of

the

necessary

data

between

national

RECAMAS

, iRCMS

and RIAT

.

RIAT Article 3

(Technical

architecture)

Article 10

(Essential

functional

features

common to

national

Union

reintegratio

n case

managemen

t system

Establishing

essential

functional

features that

Frontex n/a The use of

the

European

Search

Portal will

allow to

access the

information

stored in

EU

Where

relevant,

the

functionali

ties of the

system

should

make use

of artificial

intelligenc

EN 36 EN

RECAMAS,

iRCMS and

RIAT)

Article 13

(Essential

functional

features of

RIAT)

all three

case

managemen

t systems

should

comply with

(e.g.

issuance of

a single

identifier

allocated to

each third-

country

national for

whom a

case is

opened as

regards

return,

readmission

and, where

applicable,

reintegratio

n)

Establishing

essential

functional

features that

RIAT

should

comply with

(possibility

for a

competent

authority to

communicat

e with third

parties

competent

for

reintegratio

n assistance

on

individual

cases)

Information

Systems.

The system

should

ensure the

auto

matic

retrieval of

the

necessary

data

between

national

RECAMAS

, iRCMS

and RIAT

e systems,

in

complianc

e with

Regulation

(EU)

2024/1689

.

Frontex

RECAMAS

Article 3

(Technical

architecture)

Article 10

Reference

implementat

ion of a

return case

Frontex n/a This system

is a

reference

implementa

Where

relevant,

the

functionali

EN 37 EN

(Essential

functional

features

common to

national

RECAMAS,

iRCMS and

RIAT)

Article 11

(Essential

functional

features of

national

RECAMAS

)

managemen

t system

Establishing

essential

functional

features that

all three

case

managemen

t systems

should

comply with

(e.g.

issuance of

a single

identifier

allocated to

each third-

country

national for

whom a

case is

opened as

regards

return,

readmission

and, where

applicable,

reintegratio

n)

Establishing

essential

functional

features that

all national

RECAMAS

should

comply with

and that

Frontex

RECAMAS

reference

implementat

ion must

include

tion and is

therefore

not

containing

data

ties of the

system

should

make use

of artificial

intelligenc

e systems,

in

complianc

e with

Regulation

(EU)

2024/1689

.

Communica

tion portal

Article 3

(Technical

architecture)

Communica

tion channel

between

competent

eu-LISA n/a This system

is a

communica

tion channel

Where

relevant,

the

functionali

EN 38 EN

Article 14

(communica

tion portal)

authorities

Establish

the essential

functional

features that

the

communicat

ion portal

should

comply

with, as

well as to

establish the

single point

of contacts

to

coordinate

and

facilitate the

exchange of

data through

the

communicat

ion portal

and is

therefore

not storing

data

ties of the

system

should

make use

of artificial

intelligenc

e systems,

in

complianc

e with

Regulation

(EU)

2024/1689

CRRS Article 3

(Technical

architecture)

Article 22

(Statistics)

Central

Repository

for

Reporting

and

Statistics, to

generate

statistics

from

national

RECAMAS

, iRCMS

and RIAT

Establish

the

obligation

to

automaticall

y record

anonymised

return,

readmission

and

eu-LISA n/a This system

will ensure

that

statistics are

generated

from the

data

recorded in

national

RECAMAS

, iRCMS

and RIAT

Where

relevant,

the

functionali

ties of the

system

should

make use

of artificial

intelligenc

e systems,

in

complianc

e with

Regulation

(EU)

2024/1689

EN 39 EN

reintegratio

n-related

data from

national

RECAMAS

, iRCMS

and RIAT

into the

CRRS to

generate

statistics,

and provide

access to the

generated

statistics to

competent

authorities,

Frontex, eu-

LISA and

the

Commission

Digital systems for managing return, readmission and reintegration of third-country nationals

i.e. national RECAMAS, Frontex RECAMAS, RIAT, iRCMS, communication portal.

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act Where relevant, the functionalities of the system

should make use of artificial intelligence

systems, in compliance with Regulation (EU)

2024/1689. In case high-risk AI systems are to

be used, the corresponding requirements of the

AI Act will apply

EU Cybersecurity framework The systems will comply with the EU

Cybersecurity framework

European Digital Identity Regulation Where relevant, the systems will make use of the

possibilities offered by the European Digital

Identity Regulation concerning secure electronic

identification, authentication, and trust services

across the EU

Single Digital Gateway and IMI n/a

Others n/a

EN 40 EN

4.4. Interoperability assessment

Digital public service

or category of digital

public services

Description and

impact on

interoperability

Reference(s) to

the

requirement(s)

Interoperable

Europe

Solution(s)

Other

interoperability

solution(s)

Digitalisation of

migration

management

Establishment of

three digital

systems to

manage cases

relating to return

(‘national

RECAMAS’),

readmission

(‘iRCMS’) and

reintegration

(‘RIAT’) of third-

country nationals

staying illegally

in the Union,

including a

communication

channel

connecting these

systems

(‘communication

portal’)

Article 3

(Technical

architecture);

Article 5 (EU

Information

Systems);

Article 6

(Connection to

other national

relevant IT

systems);

Articles 7-9

(Case

management

systems);

Articles 10-14

(Case

management

systems);

Articles 15-17

(Development,

operation and

responsibilities);

Article 20

(Retention

period for data

storage);

Article 28

(Amendments to

Regulation (EU)

2018/1860)

Possibly, to be

determined at

the stage of the

development of

the systems.

The regulation

provides that

‘Technical

developments

shall take into

account any

relevant

Interoperable

Europe

solutions, as

referred to in

Article 7 of

Regulation (EU)

2024/903.’

Yes. The

systems will

make use of the

Interoperability

framework

established by

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

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

Statistics on migration

management

Automation of

statistics relating

to return,

readmission and

reintegration

Article 22

(Statistics),

Articles 29 and

30

(Amendments to

Regulations

(EU) 2019/817

No Yes. The

systems will

make use of the

central

repository for

reporting and

statistics

EN 41 EN

and 2019/818) (CRRS)

established by

Regulations

(EU) 2019/817

and (EU)

2019/818

Digitalisation of migration management

Assessment Measure(s) Potential

remaining

barriers (if

applicable)

Alignment with

existing digital and

sectorial policies

Please list the

applicable digital

and sectorial

policies identified

The three case management systems (national RECAMAS,

iRCMS and RIAT) will make full use of the EU Information

Systems (e.g. SIS or EES, in compliance with Regulations

(EU) 2018/1860, 2018/1861 and Regulation (EU) 2017/2226),

in particular through the use of the European Search Portal

(ESP) established by Regulations (EU) 2019/817 and (EU)

2019/818, which will allow to access the relevant data stored

in EU Information Systems

Should AI functionalities be embedded into the three case

management systems (national RECAMAS, iRCMS and

RIAT) and/or in the communication portal, Regulation (EU)

2024/1689 will be complied with, including as regards the

possible implementation of high-risk AI systems

Connections to national relevant IT systems and

corresponding processing activities to be carried out in

compliance with data protection rules and the conditions

determined by national law (Article 6)

n/a

Organisational

measures for a

smooth cross-

border digital

public services

delivery

Please list the

governance

measures foreseen

Access rights:

- Article 7: Competent authorities, and (upon approval

by competent authorities) Frontex, may record data in

national RECAMAS, iRCMS and RIAT. They shall be

responsible for ensuring data is accurate and up to

date.

- Article 8: Details rules for consultation of data by each

competent authority and Frontex.

- Article 9: Competent authority of origin and Frontex

shall be responsible for rectifying and erasing any

factually inaccurate data. If competent

authorities/Frontex have information suggesting

factually inaccurate data, they shall inform the

competent authority of origin (and Frontex).

- Article 14: In each competent authority, a single point

of contact shall have access to the communication

n/a

EN 42 EN

portal.

Development and Operation:

- Article 15: Frontex is responsible for the development

of the RECAMAS Model, Frontex RECAMAS,

iRCMS and RIAT.

- Article 15: Member States are responsible for the

development of national RECAMAS, and the

integration of iRCMS, RIAT, and the communication

portal into their national RECAMAS.

- Article 15: eu-LISA is responsible for the development

of the Communication Poral.

- Article 16: Program Management Board to be

established.

- Article 17: Frontex is responsible for the operational

management of iRCMS and RIAT.

- Article 17: Prior agreement of the Commission is

needed for the selection of third countries to be

connected to iRCMS.

- Article 17: Member States are responsible for the

operational management of national RECAMAS.

- Article 17: eu-LISA is responsible for the operational

management of the communication portal.

- Article 20: Rules and responsibilities as regards

retention period for data storage.

Measures taken to

ensure a shared

understanding of

the data

Please list such

measures

Article 7: Data to be recorded in national RECAMAS, iRCMS

and RIAT to include data referred to in Article 36(6) of

Regulation (EU) 2026/2280.

Article 28: Allows the keeping of relevant data from the

Schengen Information System into national RECAMAS.

Existing interoperability will be enhanced as Member States

will have the possibility to keep into national RECAMAS the

relevant information from the Schengen Information System.

n/a

Use of commonly

agreed open

technical

specifications and

standards

Please list such

measures

Interoperability is ensured as the three case management

systems (national RECAMAS, iRCMS and RIAT) will be

accessing EU Information Systems via the European Search

Portal. In addition, national RECAMAS (in which iRCMS and

RIAT will be integrated) will be connected to the

communication portal.

Common to National RECAMAS, iRCMS and RIAT:

- Article 5: Each competent authority using these

systems shall make use of the ESP to access EU

Information Systems.

- Article 10: The communication portal will provide the

possibility to securely exchange data between

competent authorities and between competent

n/a

EN 43 EN

authorities and Frontex.

- Article 10: Implementing acts to specify technical and

operational requirements necessary for the uniform

application of the essential functional features, and to

address unforeseen technical or operational gaps.

- Article 14: The communication portal shall be

integrated into each national RECAMAS, iRCMS, and

RIAT, as well as into the integrated return

management platform (IRMA). Implementing acts to

specify the technical requirements for the

establishment and connection to the communication

portal.

- Article 15: Technical development shall take into

account any relevant Interoperable Europe Solutions.

National RECAMAS:

- Article 3: Member States shall base their national

RECAMAS on: the model document and

specifications developed by Frontex (RECAMAS

Model), the IT reference implementation developed by

Frontex and based on the RECAMAS Model (Frontex

RECAMAS), or a combination of the RECAMAS

Model and specific digital modules of Frontex

RECAMAS.

- Article 6: Allows the connection of other national

relevant IT systems for the transmission of data to and

from those systems.

- Article 11: Implementing acts to detail or complement

the features of the national RECAMAS.

iRCMS:

- Article 12: Implementing acts to detail or complement

the features of the iRCMS.

RIAT:

- Article 13: Implementing acts to detail or complement

the features of the RIAT.

Statistics on migration management

Assessment Measures Potential

remaining

barriers (if

applicable)

Alignment with

existing digital and Regulations (EU) 2019/817 and (EU) 2019/818 establishing

the Central Repository for Reporting and Statistics (CRRS)

n/a

EN 44 EN

sectorial policies

Please list the

applicable digital

and sectorial

policies identified

Regulation (EC) No 862/2007 on Community statistics on

migration and international protection

Regulation (EU) 2026/2280 (Return Regulation)

Organisational

measures for a

smooth cross-

border digital

public services

delivery

Please list the

governance

measures foreseen

The governance of the CRRS is not amended and remains

regulated by Regulations (EU) 2019/817 and (EU) 2019/818

Article 22: The statistics generated by the CRRS shall be

accessible to competent authorities, Frontex, eu-LISA and the

Commission

n/a

Measures taken to

ensure a shared

understanding of

the data

Please list such

measures

Article 22: The anonymised data referred to in Article 46 of

Regulation (EU) 2026/2280 and in Article 7 of Regulation

(EC) No 862/2007, as well as anonymised data on cases

status, should be recorded, from national RECAMAS,

iRCMS and RIAT, in the CRRS

n/a

Use of commonly

agreed open

technical

specifications and

standards

Please list such

measures

Interoperability is ensured as the three case management

systems (national RECAMAS, iRCMS and RIAT) will make

use of the CRRS

n/a

4.5. Measures to support digital implementation

Description of

the measure

Reference to the

requirement

Commission’s role

in implementing the

measure

Stakeholders to

be involved

Expected timeline

Establishment of

three digital

systems to

manage cases

relating to return

(‘national

RECAMAS’),

readmission

(‘iRCMS’) and

reintegration

(‘RIAT’) of

Article 3

(Technical

architecture),

Article 7 to

Article 14 (Case

management

systems), Article

18 (Data

security), Article

19 (Keeping of

logs), Article 20

The Commission

will be part of the

Program

Management Board

and the Advisory

Group, which will

support the

continuous

development of the

systems

Member States,

Frontex, eu-

LISA,

Commission

Start of

operations by

2034

EN 45 EN

third-country

nationals staying

illegally in the

Union, including

a communication

channel

connecting these

systems

(‘communication

portal’)

(Retention period

for data storage)

Automation of

statistics relating

to return,

readmission and

reintegration

Article 22

(Statistics),

Article 29 and 30

(Amendments to

Regulations (EU)

2019/817 and

2019/818)

The Commission is

part of the

Interoperability

Program

Management Board

and the

Interoperability

Advisory Group,

which support the

continuous

development of the

interoperability

components

Member States,

Frontex, eu-

LISA,

Commission

Start of

operations by

2034

Enabling the

possibility to

retain data

relevant for

return,

readmission and

reintegration

purposes from

the Schengen

Information

System into

national systems

Article 28

(Amendments to

Regulation (EU)

2018/1860)

The Commission is

part of the SIS

Advisory Group,

which monitors and

supports the

continuous

development and

adaptation of the

SIS

Member States,

Frontex, eu-

LISA, Europol,

Eurojust,

Commission

Start of

operations by

2034

EN EN

EUROPEAN COMMISSION

Brussels, 27.10.2026 SWD(2026) 1037 final

COMMISSION STAFF WORKING DOCUMENT

Subsidiarity Grid

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) 1038 final} -

{SWD(2026) 1039 final}

Commission européenne, 1049 Bruxelles, BELGIQUE

Subsidiarity Grid

1) Can the Union act? What is the legal basis and competence of the Unions’

intended action?

1.1 Which article(s) of the Treaty are used to support the legislative proposal or

policy initiative?

The EU’s legal basis to act is established under Article 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 return, readmission and reintegration is a means to

this end.

Additionally, the proposal is based on Article 77(2) (b) and (d) of the TFEU to enable

the targeted amendment of Regulation (EU) 2019/817 of the European Parliament and

of the Council of 20 May 2019. Article 77(2)(b) and (d) of the TFEU mandates the

European Parliament and the Council to adopt measures concerning the checks to which

persons crossing external borders are subject and any measure necessary for the gradual

establishment of an integrated management system for external borders.

1.2 Is the Union competence represented by this Treaty article exclusive, shared or

supporting in nature?

Shared competence as per Article 4 TFEU.

2) Subsidiarity Principle: Why should the EU act?

2

a) Does the proposal fulfil the procedural requirements of Protocol No.

21:

Yes, for the following reasons:

• A thorough and broad consultation process was conducted with all relevant

stakeholders as part of the external ‘Study on the way towards a comprehensive,

integrated and digitalised EU migration management system’. Such consultation

process made of targeted interviews and a targeted written survey 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 in November 2025.

• A comprehensive impact assessment accompanies the legislative proposal.

Section 3 of the impact assessment addresses the question of why the EU should

act. The explanatory memorandum contains a section on the principle of

subsidiarity.

b) Does the explanatory memorandum (and any impact assessment)

accompanying the Commission’s proposal contain an adequate

justification regarding the conformity with the principle of

subsidiarity?

Yes, an adequate justification is included in the explanatory memorandum and in the

accompanying impact assessment.

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. Inefficient digital management of return, readmission and reintegration processes

will hinder the future implementation of common rules on return. 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.

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN

3

c) Can the objectives of the proposed action be achieved sufficiently by the

Member States acting alone (necessity for EU action)?

The problems to be addressed are cross-border by nature as they pertain to the

effectiveness of return, readmission and reintegration processes, which are essential for

the proper functioning of the Schengen area.

The challenges facing the EU’s common system for returns, such as fragmented IT

systems and limited data-sharing, cannot be effectively resolved at national level.

As explained above, given the magnitude of the fragmentation of the current digital

landscape, without EU coordination and a proper EU legal framework, Member States

will continue developing siloed systems, leading to inefficiencies, uneven digitalisation,

and higher costs. An EU-level intervention is therefore essential to ensure the

interconnection of relevant IT systems across Member States (including by leveraging

EU Information Systems, such as the Schengen Information System and Eurodac),

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.

Member States will be able to keep and improve their current return case management

systems or make use of an IT reference implementation provided by the EU. By offering

this choice and building on existing digital systems, the proposed approach provides a

broad degree of flexibility to Member States. This preferred course of actions has

received positive views throughout the consultation process.

4

d) Can the objectives of the proposed action be better achieved at Union

level by reason of scale or effects of that action (EU added value)?

A common framework at EU level will enhance data sharing, speed up procedures, and

reduce administrative burden. A harmonised digitalised approach to return, readmission

and reintegration 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, allowing, for instance, the EU to increase the number

of readmission case management systems established with third countries and

benefitting to all Member States.

EU-level efforts will create economies of scale, reduce costs, avoid 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.

The proposal clarifies the roles and responsibilities of the different stakeholders

(Member States, EU agencies and the Commission) and lays down a clear governance

framework for the new IT systems.

3. Proportionality: How the EU should act

a) Does the explanatory memorandum (and any impact assessment)

accompanying the Commission’s proposal contain an adequate

justification regarding the proportionality of the proposal and a

statement allowing appraisal of the compliance of the proposal with the

principle of proportionality?

Yes. To address the problems, identified, the proposal envisages a solution based on a

partially decentralised approach, which will build on existing systems at national and

EU level. For the case management of return cases, this solution will provide Member

States with the flexibility to either continue developing their existing national return

systems in line with the RECAMAS Model developed by Frontex or to adopt an off-the-

shelf RECAMAS-based IT solution developed by Frontex. This dual approach will

allow Member States to build on prior investments while ensuring convergence towards

a common framework. For the case management of readmission and reintegration cases,

the case management systems (iRCMS and RIAT) will continue to be provided at EU

level. By building on existing systems and relying on a partially decentralised approach,

the proposal does not go further than what is necessary to solve the problems identified.

5

b) Is the proposed action an appropriate way to achieve the intended

objectives?

The initiative takes duly into account the existing governance of relevant IT systems

whereby Member States are in charge of return case management systems while the EU

provides readmission and reintegration case management systems.

The initiative is limited to aspects that Member States cannot achieve satisfactorily on

their own and where the EU can do better. Member States may keep and improve their

current return systems or make use of an IT reference implementation provided by the

EU. By offering this choice and building on existing digital systems, the proposed

approach provides a broad degree of flexibility to Member States. To ensure that

Member States make use of national systems having a minimum level of efficiency,

some functional requirements are set at EU level. The management of readmission and

reintegration processes require interactions with third countries’ authorities or entities

located in third countries. A uniform way of exchanging with third countries and external

partners increases the efficiency of these processes, by facilitating a better understanding

on their side (which do not have to deal with 27 different interfaces but with only one).

For this reason, and building on the existing situation, IT systems to manage these

processes should be provided at EU level.

A regulation appears to be the most suitable legal instrument given the objective to

establish a new integrated digital case management system both at national and EU level,

mirroring thereby the choice made for all founding regulations of EU Information

Systems (e.g. Schengen Information System or Eurodac).

The initiative includes some costs to be incurred by the EU and its Member States. By

building on existing digital systems, the sunk costs will be limited as existing systems

are meant to be preserved, while being improved.

The situation of non-EU Schengen Associated Countries and EU Member States

benefitting from an opt-out on Justice and Home Affairs has been duly taken into

account.

EUROPEAN COMMISSION

01.07.2026

SEC(2026) 1037

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 1037}

{SWD(2026) 1037-1039}

Impact assessment / Digitalisation of case management in the area of return, readmission and reintegration

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 [email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / Digitalisation of case management in the area of return, readmission and reintegration

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context 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, including for return, readmission and reintegration. The initiative aims to digitalise case management for the returns, readmissions and reintegration of non-EU nationals staying illegally in the European Union. It forms part of the development of a new common approach on returns established under the Return proposal and features in Annex I of CWP 2026.

(B) Key issues The Board notes the additional information provided and commitments to make changes to the report. However, the report still contains significant shortcomings. The Board gives a positive opinion with reservations because it expects the lead Service to rectify the following aspects: (1) The report does not identify the problems in a way which is sufficiently precise.

In particular, it is not clear which problem drivers are directly linked to the lack of integrated digitalisation within the EU of the return, readmission and reintegration processes (hereafter ‘RRR’).

(2) The report does not present a complete baseline and does not describe all options in sufficient details. It does not explain well the implementation of the Communication Portal and the measures on cyber-security and data protection.

(3) The impacts of the options, in particular of the costs and benefits, are not sufficiently assessed.

2

(C) What to improve (1) The report should better identify the problems linked to the lack of integration of digital management systems of RRR. The report should improve the description of the problems, and their drivers that stem from the lack of integrated IT systems between the key actors (Agencies, in particular Frontex and eu-LISA, member states, Commisson and third countries (TC) wherever relevant), using available evidence. The report should substantiate with evidence what statistics are not currently available but are considered essential, outlining clearly whether this lack of availability is linked to the lack of integrated IT systems or to other legal or operational reasons. (2) The baseline should encompass the effects of the Interoperability Regulation as well as the changes in SIS and SIRENE expected to apply shortly. The main report should describe the measures in sufficient details to allow for their assessment, particularly how data protection and cybersecurity concerns will be addressed, how the Communication Portal will operate . The report should elaborate on the precise tasks and responsibilities of key actors, notably Frontex and eu-LISA, across the policy options. (3) The report should better assess the impacts of the proposed measures in the main report, including on fundamental rights, as well as unintended consequences. It should be clearer on the governance model envisaged for data protection. (4) The report should enhance the assessment of costs and benefits, particularly in view of the fact that the development of new IT systems -at least in those MS that have none- will come at a cost. Although ‘sunk costs’ may be analysed, they should not directly affect the rating of efficiency. The report should better reflect the different timelines in the comparison of the various options. It should also analyse the impact of future updates and upgrades. (5) The specific objectives should be better defined in line with SMART principles to allow for the possibility of monitoring progress and measuring success. Some more technical comments have been sent directly to the author Service.

(D) Conclusion The lead Service may proceed with the initiative. The lead Service must revise the report and its executive summary in accordance with the Board’s findings before launching the interservice consultation. Full title Digitalisation of case management in the area of return,

readmission and reintegration

Reference number PLAN/2024/2663

Submitted to RSB on 24 February 2026

Date of RSB meeting Written procedure

Electronically signed on 27/03/2026 11:45 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

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}

i

TABLE OF CONTENTS

1. Introduction: Political and legal context ......................................................................1

2. Problem definition .......................................................................................................6

3. Why should the EU act? ............................................................................................22

4. Objectives: What is to be achieved? ..........................................................................23

5. What are the available policy options? ......................................................................25

6. What are the impacts of the policy options? ..............................................................40

7. How do the options compare?....................................................................................50

8. Preferred option .........................................................................................................60

9. How will actual impacts be monitored and evaluated? .............................................61

ANNEX 1: Procedural information ...................................................................................63

1. Lead DG, Decide Planning/CWP references .............................................................63

2. Organisation and timing .............................................................................................63

3. Consultation of the RSB ............................................................................................64

4. Evidence, sources and quality ....................................................................................64

ANNEX 2: Stakeholder consultation (Synopsis report) ....................................................68

1. Consultation methods and stakeholders consulted ....................................................68

2. Results of the consultation activities .........................................................................71

ANNEX 3: Who is affected and how? ...............................................................................83

ANNEX 4: Analytical methods .........................................................................................86

ANNEX 5: Competitiveness check ...................................................................................89

1. Overview of impacts on competitiveness ..................................................................89

2. Synthetic assessment ..................................................................................................89

ANNEX 6: Data protection impact assessment for Option 1 ............................................90

1. Step 1: Identification of the need for a DPIA ............................................................90

2. Step 2: Description of the processing ........................................................................91

3. Step 3: Consultation process ......................................................................................94

4. Step 4: Assess necessity and proportionality .............................................................94

5. Step 5: Identification and assessment of risks ...........................................................96

6. Step 6: Identify measures to reduce risk ....................................................................96

7. Potential of artificial intelligence for digital migration management ........................97

ANNEX 7: Detailed impacts of the options ......................................................................98

1. ‘Baseline scenario’ .....................................................................................................98

2. Option 1 ‘Partially decentralised option without central EU database’ ...................107

ii

3. Option 2: ‘Partially decentralised option with central EU database’ .......................116

4. Option 3: ‘Centralised system’ ................................................................................125

5. Choice of policy instrument .....................................................................................132

ANNEX 8: Overview of policy options ...........................................................................133

ANNEX 9: Assessment of financial costs of retained policy options .............................139

1. Formulas used to estimate the total costs per policy option ....................................139

2. Methodological Approach used to estimate infrastructure costs .............................141

3. Methodological Approach used to estimate development costs ..............................142

4. Horizontal assumptions across all policy options ....................................................145

5. Assumptions specific to each policy section ...........................................................147

6. Cost items per policy option ....................................................................................155

7. Cost estimation per option .......................................................................................163

iii

Glossary

Term or acronym Meaning or definition

AI Artificial Intelligence

AMMR Asylum and Migration Management Regulation

API Application Programming Interface

BRG Better Regulation Guidelines

CEAS Common European Asylum System

CIR Common Identity Repository

CRRS Common Repository for Reporting and Statistics

CSOs Civil Society Organisations

DG HOME Directorate-General for Migration and Home Affairs of

the European Commission

DG JUST The Directorate-General for Justice and Consumers

DPIA Data Protection Impact Assessment

ECRIS-TCN European Criminal Records Information System – Third

Country Nationals

EDPB European Data Protection Board

EDPS European Data Protection Supervisor

EES Entry/Exit System

EF Environmental Factor

EMN European Migration Network

EMN-IES European Migration Network Information Exchange

System

ESP European Search Portal

ETIAS European Travel Information Authorisation System

ETTC European Technology and Training Centre

EU European Union

iv

EUDPR Data Protection Regulation for EU institutions, bodies,

offices and agencies

eu-LISA European Union Agency for the Operational

Management of Large-Scale IT Systems in the Area of

Freedom, Security and Justice

EUAA European Union Agency for Asylum

EU Information Systems EU Large-scale IT Systems: Eurodac, VIS, SIS, ECRIS-

TCN, EES, ETIAS

Eurodac European Asylum Dactyloscopy Database

FAR Frontex Application for Return

GDPR General Data Protection Regulation

ICD Interface Control Documents

ICMPD International Centre for Migration Policy Development

IOM International Organisation for Migration

IOs International Organisations

IRMA Integrated Return Management Application

ISCG Inter-Service Coordination Group

IT Information Technology

MCA Multi-Criteria Analysis

M&E Monitoring and Evaluation

MID Multiple-Identity Detector

Member States EU Member States and Schengen Associated Countries

NGOs Non-Governmental Organisations

RCMS Existing Readmission Case Management System(s)

iRCMS Future EU Integrated Readmission Case Management

System

RECAMAS Return Case Management Model

RECAP Return Mobile Application

RIAT Reintegration Assistance Tool

RRF Return and Reintegration Facility

RRR Return, readmission and reintegration

v

SACs Schengen Associated Countries

sBMS Shared Biometric Matching Service

SIRENE Supplementary Information Request at the National

Entries

S.M.A.R.T. Specific, Measurable, Achievable, Relevant, Time-bound

SMEs Small- and Medium-sized Enterprises

SPOC Single Point of Contact

TCF Technical Complexity Factor

TCN Third Country National

TFEU Treaty on the Functioning of the European Union

SIS Schengen Information System

UAW Unadjusted Actor Weight

UCP Use Case Points

UUCW Unadjusted Use Case/User stories Weights

UUPC Unadjusted Use Case Points

VIS Visa Information System

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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

(1) The Pact on Migration and Asylum was published in the Official Journal of the EU, L series, on 22 May

2024. For detailed legislative acts, see Official Journal L series daily view - EUR-Lex (europa.eu).

(2) European Commission, Communication from the Commission to the European Parliament and the Council

on a new Pact on Migration and Asylum.; COM/(2020/) 609 final, of 23 September 2020; EUR-Lex -

52020DC0609 – EN – EUR-Lex (europa.eu).

(3) Ursula von der Leyen, Political Guidelines for the Next European Commission 2024–2029, Strasbourg, 18

July 2024; e6cd4328-673c-4e7a-8683-f63ffb2cf648_en (europa.eu).

(4) European Commission, Communication from the Commission to the European Parliament and the Council:

The EU strategy on voluntary return and reintegration; COM(2021) 120 final, 27 April 2021; EUR-Lex -

52021DC0120 - EN - EUR-Lex (europa.eu).

(5) European Commission, Policy Document: Towards an operational strategy for more effective returns;

COM(2023) 45 final, of 24 January 2023; EUR-Lex - 52023DC0045 - EN - EUR-Lex (europa.eu).

(6) European Commission, Communication from the Commission to the European Parliament, the Council, the

European Economic and Social Committee and the Committee of the Regions; Commission work programme

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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

2026 Europe's Independence Moment; COM(2025) 870 final, of 21 October 2025; EUR-Lex - 52025DC0870

- EN - EUR-Lex.

(7) European Commission, Communication from the Commission to the European Parliament and the Council:

European Asylum and Migration Management Strategy, COM(2026) 45 final, 26 January 2026; ce0d294e-

5dd9-4e2a-bf68-53d9d16fc95a_en.

(8) Regulation of the European Parliament and of the Council establishing 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, OJ L, 2026/2280, 15.10.2026, ELI:

http://data.europa.eu/eli/reg/2026/2280/oj). Article 40(1)(c) of the Return Regulation.

(9) Please also refer to the Data Protection Impact Assessment in Step 1: Identification of the need for a DPIA.

(10) 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); https://data.europa.eu/doi/10.2837/8436041;

https://data.europa.eu/doi/10.2837/0124908.

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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

(11) As indicated in the European Asylum and Migration Management Strategy, ‘the Commission plans to

explore, starting in 2026, the feasibility of a dedicated proposal for digitalisation in the area of asylum, also

in light of such proposal being prepared in the area of return’.

(12) 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; OJ

L 295, 14.11.2019, p. 1; https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R1896.

(13) European Commission, Communication from the Commission to the European Parliament, the Council, the

European Economic and Social Committee and the Committee of the Regions; Common Implementation

Plan for the Pact on Migration and Asylum; COM (2024) 251 final, 12 June 2024; EUR-Lex - 52024DC0251

– EN – EUR-Lex (europa.eu).

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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, Frontexis currently developingan 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.

(14) Council Decision 2008/381/EC, Article 2 (e) and Article 8.

(15) 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; OJ L 1358, 22.5.2024; https://eur-lex.europa.eu/eli/reg/2024/1358/oj/eng.

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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-

(16) 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; OJ L 312/1,

7.12.2018; https://eur-lex.europa.eu/eli/reg/2018/1860/oj/eng. 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; OJ L 312/1, 7.12.2018;

https://eur-lex.europa.eu/eli/reg/2018/1861/oj/eng.

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; OJ L 312/1, 7.12.2018; https://eur-lex.europa.eu/eli/reg/2018/1862/oj/eng.

(17) 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); OJ L 218/60, 13.8.2008; https://eur-lex.europa.eu/eli/reg/2008/767/oj/eng.

(18) 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; OJ L 327/20, 9.12.2017; https://eur-

lex.europa.eu/eli/reg/2017/2226/oj/eng.

(19) 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; OJ L 236/1, 19.9.2018;

https://eur-lex.europa.eu/eli/reg/2018/1240/oj/eng.

(20) 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; OJ L 135/1, 22.5.2019; https://eur-

lex.europa.eu/eli/reg/2019/816/oj/eng.

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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

(21) 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; OJ L 135/27, 22.5.2019; https://eur-lex.europa.eu/eli/reg/2019/817/oj/eng, and 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; OJ L 135/85,

22.5.2019; https://eur-lex.europa.eu/eli/reg/2019/818/oj.

(22) Please also refer to

Option 1 can be visualised as follows ():

Figure 5 – Baseline scenario

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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;

(24) Return Regulation, Article 36.

Incomplete and siloed digitalisation

D ri ve rs

Inadequate system functionalities

Lack of sufficiently clear legal bases for the sharing of data

and development of IT systems

Pr ob

le m s

The information needed to carry out

efficiently RRR is not easily accessible to

all relevant authorities

Excessive administrative

burden, delays and inefficient

monitoring of cases

More granular and swiftly available

statistics are needed

C on

se qu

en ce

s Inefficient and fragmented digital migration management for RRR

Hindered future implementation of common rules on return

Impact on the proper functioning of the rules of the Pact on Migration and Asylum

Impact on the functioning of the Schengen area

8

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

(25) 18 Member States indicated that the data available is sufficient to manage RRR cases at national level, as

opposed to six Member States which reported to experience limitations; Digitalisation Study, Table 127.

(26) ‘n=24’ means that the data was available for 24 Member States.

(27) Digitalisation Study, Table 139.

(28) Estimates based on the number of SIS hits on alerts on return; SIRENE mail statistics produced by eu-LISA.

9

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

Type of Data Number of Member States

collecting and using data

Number of Member

States sharing data

Legal status and documentation (e.g. existence of

residence permit, approved asylum application, etc.)

24 17

Biographic data (e.g. name, date of birth,

nationality)

23 22

Information on criminal records 23 20

Biometric data (e.g. fingerprints, facial recognition) 22 21

Travel history and entry/exit records 18 9

Health and medical records 18 5

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

(29) Digitalisation Study, Tables 130 and 131. Survey results indicate that 55% (N=13) of Member States

identified data completeness as a key issue and 41% (N=9) highlighted data accuracy as a major concern (see

Figure 50 in Annex V of the Digitalisation Study).

(30) Digitalisation Study, Table 131.

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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).

(31) Article 6 and Article 16 of Regulation (EU) 2018/1860.

(32) As confirmed by the information collected in preparation of joint committees of readmission agreements and

arrangements as well as in relevant Council Working Groups and Commission Expert Groups.

(33) 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.

(34) Digitalisation Study, Table 133.

11

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

(35) In the framework of the Digitalisation Study, most Member States were unable to provide data or estimates to

quantify the extent of manual intervention. One Member State reported that approximately 70% of its asylum

and return processes are conducted manually, with only 20% partly automated and 10% fully automated. This

situation likely reflects a broader reliance on manual processes across many Member States, although the

degree of manual processing may vary significantly between Member States, leading to a fragmented

landscape and differing levels of maturity in their systems. Digitalisation Study, Section 1.1 of Part 2.

(36) Bilateral meetings conducted with national competent authorities in 2025.

(37) Eurostat, [migr_eiord] Third country nationals ordered to leave - annual data (rounded).

(38) Counting 8h per working day.

(39) Based on the average hourly labour cost in 2024 i.e. €33.5: EU hourly labour costs ranged from €11 to €55

in 2024 - News articles - Eurostat.

(40) Digitalisation Study, Section 1.1 of Part 2.

(41) Eurostat, [migr_eirtn] Third country nationals returned following an order to leave - annual data (rounded).

(42) Based on the average hourly labour cost in 2024 i.e. €33.5: EU hourly labour costs ranged from €11 to €55 in

2024 - News articles - Eurostat.

(43) Digitalisation Study, Section 5.1.1 of Annex V.

(44) Digitalisation Study, Section 1.2.3 of Part 2.

(45) Digitalisation Study, Annexes to Part 2, Annex V, Figure 51.

12

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).

(46) For example, it was estimated in one interview that processing each case in the current scenario takes around

30 minutes longer than would actually be necessary in case the process would be more automated.

(47) Eurostat, [migr_eiord] Third country nationals ordered to leave - annual data (rounded).

(48) Frontex operational data.

(49) Eurostat, [migr_eiord1] Third country nationals ordered to leave by citizenship, age and sex - quarterly data

(rounded).

(50) Frontex operational data.

(51) Digitalisation Study, Figure 53.

(52) Digitalisation Study, Table 146.

(53) Digitalisation Study, Section 1.2.2 of Part 2.

13

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.

(54) International Organisation for Migration. Global Migration Data Portal (2024). The Essentials of Migration

Data - Chapter 1: The relevance of migration data and statistics; accessed 22 October 2025. Available at:

https://www.migrationdataportal.org/handbook; 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, p.5.

(55) Digitalisation study, Section 1.2.2 of Part 2.

(56) 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.

(57) 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, page 6.

14

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

(58) Digitalisation Study, Table 122.

(59) Integrated systems manage RRR cases within a single national system, while separate systems involve

distinct, independent IT systems, requiring switching from one system to another to process a RRR case.

15

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)

Systems Number of MS

National system based on the RECAMAS

Model

12

National system with a certain degree of

alignment on the RECAMAS Model

26

RCMS (at least with one third country) 27

RIAT 27

FAR 26

IRMA 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.

(60) Digitalisation Study, Figure 52.

(61) Digitalisation Study, Table 131.

(62) Digitalisation Study, Table 133.

(63) Digitalisation Study, Section 1.2.1 of Part 2.

16

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.

(64) Digitalisation Study, Section 1.1 of Part 2.

(65) Digitalisation Study, Table 123.

(66) Digitalisation Study, Table 121.

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

(68) Regulation (EC) No 862/2007 of the European Parliament and of the Council of 11 July 2007 on Community

statistics on migration and international protection and repealing Council Regulation (EEC) No 311/76 on

the compilation of statistics on foreign workers, OJ L 199, 31.7.2007,

http://data.europa.eu/eli/reg/2007/862/oj.

17

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 ascontroller and as processor) is

(69) Eurostat, [migr_eiord] Third country nationals ordered to leave - annual data (rounded).

(70) Eurostat, [migr_eirtn] Third country nationals returned following an order to leave - annual data (rounded).

(71) Eurostat, [migr_eiord1] Third country nationals ordered to leave by citizenship, age and sex - quarterly data

(rounded).

(72) Eurostat, [migr_eirtn1] Third-country nationals returned following an order to leave, by type of return,

citizenship, country of destination, age and sex - quarterly data.

(73) Commission Implementing Decision establishing the 2024 thematic Schengen evaluation report 'Bridging

national gaps: towards an effective EU return system through common solutions and innovative practices',

C(2024) 9171 final.

(74) Digitalisation Study, Section 1.2.1 of Part 2.

(75) Digitalisation Study, Section 1.2.1 of Part 2.

18

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

(76) Digitalisation Study, Annex V, Figure 59.

(77) For instance, between the standard return procedure and the return border procedure.

(78) Digitalisation Study, Table 147.

(79) Digitalisation Study, Table 148.

(80) Digitalisation Study, Table 149.

19

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

(81) Article 41(2) of Regulation (EU) 2018/1861 and Article 56(2) of Regulation (EU) 2018/1862 provide that ‘a

Member State shall not copy alert data or additional data entered by another Member State from its N.SIS or

from the CS-SIS into other national data files’.

(82) Digitalisation Study, Table 145.

20

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

(83) Digitalisation Study, Table 129.

(84) Return Regulation, Articles 36-39.

(85) For instance, Article 87(1)(b) of the EBCG Regulation, which frames the purposes for which Frontex may

process personal data, does not refer expressly to reintegration.

(86) As confirmed by the information collected in preparation of joint committees of readmission agreements and

arrangements as well as in relevant Council Working Groups and Commission Expert Groups.

21

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

(87) Communication from the Commission to the European Parliament and the Council, The European Annual

Asylum and Migration Report (2025), Brussels, 11.11.2025 COM(2025) 795 final, page 18.

(88) Eurostat, [migr_eiord1] Third country nationals ordered to leave by citizenship, age and sex - quarterly data

(rounded).

(89) Frontex operational data.

22

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

(90) Digitalisation Study, Section 2.2 of Part 2.

23

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.

24

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

(91) 27 return case management systems, six RCMS, RIAT, at least 4 EU Information Systems (SIS, VIS,

Eurodac, EES), FAR, IRMA.

25

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

(92) The figure depicts the current baseline scenario, where each Member State [MS1. MS2 and MS3] operates

their own case management system on return (not based on the RECAMAS model in all cases, and with

differing level of automation). The national case management systems are not connected, and therefore

Member States cannot share information directly, but need to do it through the EU Information Systems, for

example the SIS and the SIRENE Channel. In addition, the readmission (RCMS) and reintegration (RIAT)

IT systems are not connected to the national case management, which causes gaps in information sharing at

national level. Certain IT systems, including ETIAS and RECAP, are not operational as of today but will be

a near future.

Example of the standard digital processing by Member State A of a RRR case concerning TCN X, on which Member State B possesses some information

• Step 1: Member State A creates and processes the case of TCN X in its national RECAMAS. The information from the EU Information Systems can be accessed but is not queried and retrieved directly into the national RECAMAS and it has to be inserted manually.

• Step 2: Member State A may need additional information from Member State B (e.g. for identification purposes), which is not available in EU Information Systems. The information is often not exchanged.

• Step 3: the readmission process, and where applicable, reintegration process

are managed through iRCMS (which only exists with six third countries) and RIAT. The case handler has to log off from national RECAMAS and log on to iRCMS and RIAT and copy manually the data to these systems.

26

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

27

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’.

Example of the standard digital processing by Member State A of a RRR case concerning TCN X, on which

Member State B possesses some information

• Step 1: Member State A creates and processes the case of TCN X in its national RECAMAS. Thanks

to the ESP, the information on TCN X is queried and retrieved from the EU Information Systems

directly into the national RECAMAS.

• Step 2: Member State A may need additional information from Member State B (e.g. for identification

purposes), which is not available in EU Information Systems. Member State A requests Member State

B to share this additional information. The request and the exchange of information is done through

the Communication Portal.

• Step 3: the readmission process and, where applicable, the reintegration process are managed through

iRCMS and RIAT without the need to log off and log on or to manually copy data as these systems

will be integrated into national RECAMAS.

28

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.

(93) The figure depicts Policy option 1, in which each Member State [MS1. MS2 and MS3] would operate a

‘national RECAMAS’ with a minimum set of functional requirements. The systems for readmission (iRCMS)

and reintegration (RIAT) will be integrated in the ‘national RECAMAS’ allowing for a seamless case

management of the RRR process. The ‘national RECAMAS’ will be connected to the ESP, allowing it to

search and retrieve information from all relevant EU Information Systems. The Communication Portal will

allow Member States to exchange relevant information.

29

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.

(94) 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; OJ L 295, 21.11.2018, p. 99; https://eur-

lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1726.

(95) 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; OJ L 312/1,

7.12.2018; https://eur-lex.europa.eu/eli/reg/2018/1860/oj/eng.

30

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.

Example of the standard digital processing by Member State A of a RRR case concerning TCN X, on which

Member State B possesses some information

• Step 1: As under Option 1, Member State A creates and processes the case of TCN X in its national

RECAMAS. Thanks to the ESP, the information on TCN X is queried and retrieved from the EU

Information Systems directly into the national RECAMAS.

• Step 2: Member State A may need additional information from Member State B (e.g. for identification

purposes), which is not available in EU Information Systems. Member State A requests Member State

B to share this additional information which becomes accessible to Member State A in its national

RECAMAS thanks to the new EU central database (and not thanks to the Communication portal as

under Option 1).

• Step 3: As under Option 1, the readmission process and, where applicable, the reintegration process

are managed through iRCMS and RIAT without the need to log off and log on or to manually copy

data as these systems will be integrated into national RECAMAS

Option 2 can be visualised as follows (96):

(96) The figure depicts Policy option 2, in which each Member State [MS1. MS2 and MS3] would operate a

‘national RECAMAS’ with a minimum set of functional requirements. The systems for readmission (iRCMS)

and reintegration (RIAT) will be integrated in the ‘national RECAMAS’ allowing for a seamless case

management of the RRR process. A new database would be created containing all relevant RRR information,

inserted through the ‘national RECAMAS’. Member States’ competent authorities would have direct access

to the RRR database and would exchange information directly through it. The RRR database would become

part of the Interoperability framework, leveraging the interoperability components MID, CIR, sBMS, ESP

and the CRRS.

31

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

32

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).

Example of the standard digital processing by Member State A of a RRR case concerning TCN X, on which

Member State B possesses some information

• Step 1: Member State A creates and processes the case of TCN X directly in the EU centralised case

management system. Thanks to the ESP, the information on TCN X is queried and retrieved from

other EU Information Systems.

• Step 2: Member State A may need additional information from Member State B (e.g. for identification

purposes), which is not available in EU Information Systems. Member State A requests Member State

B to share this additional information which becomes accessible to Member State A through the new

EU central database.

• Step 3: the readmission process and, where applicable, the reintegration process are managed directly

in the EU centralised case management system.

Option 3 can be visualised as follows (97):

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

Source: Commission

(97) The figure depicts Policy option 3, in which a single common case-management system would be developed

at EU level, to which all Member States are connected through a uniform national interface. The single

common case-management system would also include an RRR database.

33

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):

(98) The figure depicts the discarded policy option for a decentralised system, in which each Member State [MS1.

MS2 and MS3] would operate a ‘national RECAMAS’ with a minimum set of functional requirements. The

systems for readmission (iRCMS) and reintegration (RIAT) would also be developed at national level, with

no EU component. A dedicated RRR database will be established storing all data recorded in national

RECAMAS, iRCMS and RIAT.

34

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.

(99) Digitalisation Study, Section 4.3 of Part 2.

35

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.

Assessment of impacts

E co

n o

m ic

0 Option 0 has no significant economic impact.

This is based on the assessment that the various effects are all rather limited in scale.

The impact on public budgets under the baseline scenario is limited, as existing

infrastructures are already in place. However, the maintenance costs are estimated at

EUR 3.32 million per Member State per year (EUR 24 million in total) (100).

At the same time, the management of return has by its nature no relevance for the activity

of Small- and Medium-sized Enterprises (‘SMEs’), competitiveness or property rights.

The very limited digitalisation in this field also offers no stimulus for innovation or

growth, as it is not related to new technological developments or investments in IT

systems.

(100) Please refer to Table 37 - Overview of costs per stakeholder and policy option for more details.

36

S o

ci et

al

0 The baseline scenario has a negative societal impact, primarily due to the fact that

insufficient digital management of RRR processes leads to the problems identified in

Section 2, which may continue to fuel public discontent, widen social divides, and erode

trust in institutions, ultimately weakening the EU’s ability to tackle a politically sensitive

issue. Looking forward, the numbers of irregular TCNs is expected to continue to place

pressure on social welfare systems and public services, diverting resources from other

critical areas such as healthcare, education, and housing. At the same time, a negative

societal impact is due to the exploitation of irregular TCNs, who will continue to support

sectors such as agriculture, care work, and construction.

E n

v ir

o n

m en

t

al .

0 Option 0 has a negligible negative environmental impact.

The energy consumption of the necessary IT systems may vary with the level of

modernity and manual processes and represent missed opportunities to implement more

sustainable digital solutions but is overall too limited under the baseline scenario to have

any environmental impact.

S ec

u ri

ty

0 The baseline scenario has a negative impact on security across the EU.

The lack of sufficiently effective return procedures weakens the EU’s ability to manage

RRR processes, leading to concrete security risks within the Member States due to delays

in return procedures and insufficient monitoring of individuals posing security threats.

Due to the current shortcomings in terms of data-sharing, the EU's ability to carry out

effective risk assessments is diminished, impairing efforts to identify high-risk

individuals, reducing the overall effectiveness of security measures.

The security of RRR processes is undermined by structural and operational challenges,

increasing the risk of errors, misuse of information, and personal data breaches.

F u

n d

am en

ta l

ri g h

ts

0 Option 0 generally adheres with fundamental rights. However, concerns have been raised

regarding the protection of personal data, particularly for TCNs. The fragmented digital

landscape may lead to difficulties to identify the roles and responsibilities of different

actors (i.e. controllers and processors). The insufficient digitalisation may hinder the

ability of TCNs to make use of their data subjects rights (e.g. right of access), and the

limited functionalities of existing IT systems may prevent controllers from swiftly

addressing data subjects’ requests.

Moreover, the absence of a harmonised approach at EU level complicates monitoring

efforts and heightens the risk of violations going undetected, thereby undermining the

consistent protection of TCNs' rights across Member States.

Feasibility

F ea

si

b il

it y

0 N/A

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’

Assessment of impacts

37

E co

n o

m ic

0 Option 1 has no significant, direct or indirect, economic impact because the

various effects of return policies on macro-economic parameters are rather

limited in scale. 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.

A minor economic stimulus may benefit larger IT companies but is unlikely to

benefit SMEs, with no significant impact on competition, technological

developments, consumers, innovation, or education. In this regard, it can also be

referred to the competitiveness check undertaken (see Section 2 of Annex 5).

S o

ci et

al 1 Option 1 is expected to contribute to strengthening public trust in EU and

Member States’ migration management, by improving the management of RRR

processes. Labour market effects are limited, with marginal impacts on

employers relying on irregular TCNs but greater and swifter certainty for legal