Among the reasons for the Return Regulation's popularity is one statistic: of all the non-EU citizens ordered to leave the EU in 2025 (491,950), only around 28% did so. The regulation promises to increase that share by accelerating deportations and allowing member states to negotiate “return hubs” with third countries: centres that can receive “illegal” immigrants.

These aren't just attractive options for EU countries looking to remove migrants, but also good deals for third countries, which can expect financial investments in return.

In very un-EU fashion, the regulation was fast-tracked, specifically the parts that concern return hubs. Now that the EU has laid out the framework, it’s up to member states to seek out their own agreements.

Last Friday (4 September), they did just that. Ministers from Denmark, Germany, the Netherlands, Austria, and Greece met in Copenhagen to start “technical discussions” with third countries. Their plan: sign agreements this year, start deporting next year.

This is all happening fast. Thankfully, we can do some time travelling to understand how these deportations could work. We drafted a hypothetical return journey from the moment of first detection up to the arrival in a third-country return hub.

As we go along, it might become progressively harder to understand why we're doing any of this given the potential for human rights abuses, litigation, delays, logistical nightmares, and damages to the entire international humanitarian framework.

The following story about “Cali” is a fictional aggregate of four real testimonies by migrants who have faced returns.

Is Cali “illegal”?

It’s 2027. Cali is a migrant from Afghanistan living in Germany, which has started deporting to third-country hubs in Rwanda and Uganda.

To be deported under the Return Regulation, a person has to be staying in the EU illegally. That doesn't mean they are illegal, as in criminal, though supporters of increased deportations often frame people like Cali that way. In fact, the EU itself emphasises that the vast majority of irregular migrants aren’t criminals.

“Calling someone ‘illegal’ for seeking protection, or for using the only route available to them, shapes how their poor treatment can become normalised and seen as acceptable,” Marta Welander, director of EU advocacy at the International Rescue Committee (IRC), tells us – a risk Cali will become all too familiar with.

Someone’s status is illegal when they don’t fulfil “conditions for entry, stay or residence.” That can mean a lot of things: irregular arrivals, an expired residence permit, a rejected asylum application – or, in Cali’s case, having arrived in one EU country and moving to another, known as secondary movement.

Identified, filed, ordered

Cali first set foot on EU territory in Greece, but then moved to Germany.

Why did Cali not simply stay in Greece? Usually, people engage in secondary movement to reunite with family, join friends, or find better employment opportunities.

But often, it’s for a much simpler reason: the conditions where they arrive can resemble prisons. Greece, despite some improvements in the past decade, continues to have a notorious track record for unhygienic, overcrowded, and inhumane detention facilities. Cali wouldn't be the first to face those conditions.

In Germany, Cali's status is revealed to law enforcement during a police check. Detecting illegal stays like his has become much simpler since the EU’s Interoperability Framework centralised previously separate databases into one single, searchable set in late 2026, as part of the EU's expansion of its migration surveillance infrastructure.

He receives a so-called return decision ordering his deportation on the grounds of his illegal stay. But returning him to Greece would violate non-refoulement, the guarantee under international human rights law against returning migrants to countries where they could face harm.

A review by the EU’s own asylum agency in 2025 included Belgium, Bulgaria, Hungary, Poland, and Greece on that list.

In other words, conditions for asylum procedures, reception, and healthcare even within the EU can be miserable and risk refoulement, so the question becomes: where else could he be returned to?

Cali now has 30 days to choose: he could challenge the decision, await his return to a third country, or return to Afghanistan voluntarily. The last option has gained favour among member state governments: in 2026, multiple countries began paying people “reintegration assistance” to leave on their own.

That may work for those whose country of origin is at least somewhat safe, but it won’t work for Cali. The Taliban-led government of Afghanistan has a track record of torture, political persecution, and arbitrary detentions – especially for dissidents, or anyone who appears to be one.

Cali challenges the return decision, but it gets denied. He cannot be sent back to Afghanistan, as that would violate non-refoulement. So German authorities begin organising his return to a third country. Since the Return Regulation entered into force, the maximum amount of time a migrant can be detained before being deported has risen from 18 to 30 months. Crucially, the reasons for detaining people were also expanded, risking more arbitrary detentions.

Where does Cali actually go?

After classifying Cali as eligible for return, German authorities put him in a detention facility to ensure he doesn't flee. There, he waits for months before knowing whether he'll be sent to Rwanda or Uganda. The Return Regulation doesn’t require member states to know in advance where they'll send someone, and there are no set criteria to determine the destination.

The only rule is that non-refoulement isn’t violated: people cannot be returned to countries where they would face torture or other forms of violence. Other migrants Cali has met along the way told him both Rwanda and Uganda have highly questionable human rights records, to say the least.

At which point you might think: how is that not illegal? Well, it probably is. While the regulation vaguely calls for respect for international human rights standards, it's hard to see how that argument can be made in the candidate countries. Experts warn that this could lead to legal challenges.

But in this timeline, the return hubs worked out. Cali receives a destination: Rwanda.

Cali lands in Rwanda. What now?

Good question. No one knows how long he'll stay. Weeks, months, years? The regulation doesn’t specify a duration. What it does specify is that the return process is “over” – from the sending country's side – as soon as Cali arrives at the centre. The EU’s legal responsibility ends.

Let's travel back to the present day and take stock.

Who is going to monitor the safety of these camps? Denmark’s migration minister Morten Bødskov, who hosted the meeting with German, Dutch, Austrian, and Greek ministers on 4 September, said that the hubs would be under the supervision of the International Organisation for Migration (IOM) and the United Nations Refugee Agency (UNHCR).

That would be a start, but we asked both, and they denied it. The UNHCR “has not been approached yet with details of such a proposal,” and an IOM spokesperson told us that “no decisions have been taken regarding any potential operational role for IOM in proposed return hubs.”

Even if organisations like the IOM are present, that doesn't guarantee human rights standards. There are multiplecases, this year alone, where the IOM encouraged and actively assisted returning people from the US to countries where they face humanitarian risks.

In any case: once people are returned, following what happens to them becomes nearly impossible. Return hubs become “black holes: they sit outside EU territory, where policymakers cannot guarantee that people's rights will be upheld,” Welander of the IRC told us. “We've seen what this looks like in practice.”

The IRC visited the Italian detention facility in Albania, which functions similarly to a return hub. They saw “consistent reports of self-harm and suicide attempts, testimonies of severe psychological distress, and a lack of sustained psychiatric support. Around 80 people were detained there at the time of our second visit, many for months, with little transparency from Italian authorities on numbers, nationalities, selection criteria, or repatriation rates,” Welander explained.

Our governments are pushing for more.

There’s an argument to be made that in some cases, return decisions can be enforced better. Remember how only 28% of people who received a return decision actually left in 2025? The two countries with the highest return orders and simultaneously least efficient return implementations are Algeria and Morocco.

Both governments are notoriously difficult in negotiating flights: from not accepting charter flights for returnees to demanding that returns are processed within 24 hours, which makes them practically impossible. Instead of fixing these issues, the EU is creating a new massive, intransparent deportation system.

An American template

Yael Schacher, historian and director at Refugees International, spoke to us about the many, many deals that the Trump administration signed with third countries for deportations. Among them: EU hopefuls like Rwanda or Uganda.

“These deals have a clear message: at best, refugee protection is temporary,” she said. After Trump cut USAID funding, the crucial American humanitarian development programme, American funds became contingent on third countries hosting migrants.

These American deals give Europe “a recent, functioning template for exactly this kind of transactional arrangement,” Welander explained.

Return hubs put more at stake than the lives of individual migrants. Schacher argued that “these deals should be seen, in my view, as not only migration management and deterrence, but as an attack on the Refugee Convention. They flip the whole humanitarian architecture that was developed after World War II on its head.”