An asylum seeker settled in Germany could soon be sent back to Italy, the country where they first set foot in Europe. Eight EU states have quietly revived that rule. Rome is struggling to cope, and it is far from ready.
The shift follows the EU Pact on Migration and Asylum, which entered into force this summer. Brussels had promised the reform would ease pressure on countries such as Italy, Spain, and Greece, the main points of arrival for new migrants. Instead, it has triggered exactly the kind of transfers those countries hoped to avoid.
Officials informally call the rule the ‘Dublin’ mechanism. Under it, the country where a migrant first enters the EU stays responsible for their asylum claim. That responsibility lasts 20 months after irregular entry, or 12 months if the migrant arrived via a sea rescue. The obligation carries over largely unchanged from the old Dublin Regulation, hence the term ‘Dubliners’ for those affected by it.
In brief
Returns are already underway. Germany, the Netherlands, Sweden, Austria, Finland, Ireland, Belgium, and Slovenia have all begun sending migrants back. So has Switzerland, a member of the Schengen area though not the EU.
Germany was the first to follow the rule. It started the ball rolling in recent weeks, announcing plans to return three migrants to Italy. Rome had unilaterally decided not to accept such transfers back in 2022. Under the terms of the new Pact, transfers were set to resume from 12 June, though Rome and Berlin have since clashed over what exactly that starting date covers. The Austrian interior ministry followed suit, confirming it had already carried out four transfers to Italy since the same day. Sweden has also resumed the practice sending back one person to Italy in August.
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The reasoning behind it
In December 2022, shortly after Prime Minister Giorgia Meloni took office, Italy suspended all returns of asylum seekers, thus violating the Dublin Regulation on asylum. The fact that Italy is now, in principle, willing to accept returns is linked to the new Pact, which provides financial support and other forms of facilitation for Italy and other countries of first arrival of asylum seekers. However, this is conditional on the countries themselves complying with their obligations. Rome intends to readmit only asylum seekers who arrived after the day that the Pact got into force.
The dispute comes down to how the transition is counted. Germany insists Italy must still take back migrants who arrived before the Pact took effect, while Rome wants the count reset to zero for anyone who arrived before 12 June.
The numbers
Eurostat’s annual report, published in July 2026, shows which countries submitted the most outgoing requests under the Dublin procedure. Germany led with 35,933; France followed with 30,084, and Belgium with 12,285. Together, these three countries accounted for 70 per cent of all transfer requests in 2025. Secondary movements, meaning migrants leaving their country of first arrival, mainly drove the trend. Latvia (23), Estonia (33), and Slovakia (49), on the other hand, submitted the fewest outgoing requests.
It remains unclear whether the Pact’s promised solidarity can fix what Dublin could not.
Germany carried out the largest number of outgoing transfers (5,377), followed by France (3,881) and the Netherlands (1,865). At the other end of the scale, Ireland carried out none, while Portugal managed only one and Spain two.
The aggregate figures tell a similar story. Europe registered 111,708 ‘Dubliners’ in 2025, of which only 16,620 were actually transferred back to their first country of arrival. Eurostat notes the figures are estimated, as official data remain unavailable.
Italy received more such requests than any other member state that year. Eurostat estimated a staggering 24,152 transfer requests, followed by Germany (16,519), Croatia (12,358), Spain (10,684), and Greece (10,113). Together, these five countries accounted for 64 per cent of all incoming requests in 2025. A total of 115,625 transfer requests were received in 2025, a 31 per cent drop compared with 2024.
The paralysis of the system is evident. Italy suspended requests over its inability to process them back in 2022, and it remains unclear whether the Pact’s promised solidarity can fix what Dublin could not.
