In March 2025, the European Commission proposed a new Return Regulation. Among other planned measures, the one of the so-called ‘return hubs’ - centres built in third countries, where to forcibly transfer people targeted by expulsion measures - is of particular concern. In parallel, Italy is experimenting with the so-called ‘Albania model’, which provides for the forced transfer of migrants to centres located on Albanian territory but under Italian jurisdiction. These are similar strategies with different operational modalities, but both with very serious consequences in terms of human rights.
The ‘Albania model’ had two phases: the first involved the transfer of migrants intercepted at sea, from so-called safe countries of origin, for the accelerated examination of their asylum applications in Albania. This phase soon entered into a crisis due to its weak legal infrastructure. The second phase, still active today, consists of transferring people already detained in Italian Centres for Repatriation (CPRs) to Albania, without any transparent ground, with no adequate legal protection, and with the use of coercive means.
An important difference between the two models concerns jurisdiction. In the case of the ‘Albania model’, Italy formally extended its jurisdiction to the centres in Albania: while not avoiding fundamental rights violations, this allowed the activation of legal remedies before Italian courts, which led to the release of many people and the ‘crisis’ of the model. In contrast, the European ‘return hubs’ do not provide for clear jurisdiction on the part of Member States nor do they define who is legally responsible in the event of violations. This makes the proposed hubs even more opaque and potentially removed from any effective jurisdictional control.
Although formally different, the Albania model and European return hubs share the same logic: governing migrant bodies through detention, marginalisation and the use of grey legal spaces, where protections are minimal or absent. Both reduce access to asylum, increase detention, and empty fundamental rights of meaning.
The balance after nine months of the ‘Albania model’ is dramatic: systematic violations of rights, radical opacity, generalised detention, and frequent acts of self-referral by those detained. The convergences between the Italian model and the EU proposal indicate a common design to make the contraction of rights structural. Stopping this process is a political and legal priority.
Read the full analysis here.