European Council on Refugees and Exiles (ECRE) feedback on the Proposal establishing the Asylum and Migration Fund (AMF) COM (2018)
The following feedback is based on insights from ECRE member organisations, who are working on asylum, integration and migration matters across EU Member States many of which are beneficiaries of AMIF funding. It is also informed by research conducted in cooperation with UNHCR and published in the Follow the Money Report (available online) beginning of 2018.
ECRE welcomes the suggested increase in resources available for asylum and migration as EU funding can play a considerable role in ensuring fair and effective asylum systems in Europe and contribute to the harmonization of standards in relation to asylum, reception conditions and integration. The extent to which the AMF will be able to do this will depend on a clear articulation of the funds objectives to promote protection space within Europe, support integration and expand safe and regular pathways to the EU. To ensure Member States allocate resources to support these priorities, allocation and spending requirements for the asylum and integration objective should be included in national programmes.
The way in which the level of contribution to Member States’ national programmes will be calculated should most accurately reflect the needs related to asylum, reception and integration. An overemphasis on return as suggested in the current proposal risks further undermining asylum processes to issue more return decisions and incentivizes forced returns.
The EU has various external funding instruments which are supposed to contribute to the EU’s objectives as an external actor in line with Article 21 TEU. Internal asylum and migration funding follows different objectives. To avoid undermining effective EU external action, AMF support to activities outside the EU should be clearly defined and limited to issues that are in the domain of internal affairs. In addition, the protection nature of resettlement should be safeguarded, instead of portraying it as a tool to achieve EU migration management objectives.
Finally, more could be done to support cooperation with civil society in planning, implementing and monitoring funding. Increasing transparency on how funding is spent would support this and provide greater accountability.
ECRE therefore makes the following recommendations:
1. Objectives of the fund: The objective of contributing to common standards on policy on asylum, subsidiary protection and temporary projection and commitment to the rights and principles enshrined in the Charter of Fundamental Rights of the EU should be included prominently in the proposal, including as the central objective.
2. Allocation of funding to national programmes: The suggested criteria for the allocation of funding to the programmes under shared management should be revised so that they do not incentivize return decisions and forced returns.
3. Allocating resources to integration and asylum priorities: Minimum allocation and spending requirements for the asylum, integration and legal migration objective in national programmes should be included to ensure that Member States adequately invest in these areas.
4. Third countries associated with the fund: Reference to AMF supporting activities outside the EU should be limited and the specific activities should be defined. Where the possibility for external spending is mentioned, the necessary human rights safeguards need to be included.
5. Resettlement as a humanitarian protection tool: References to using resettlement to achieve EU migration management objectives should be deleted.
6. Partnership with civil society: Barriers to civil society involvement in AMF, such as co-financing rates should be addressed and a reasonable minimum percentage of national programme funding for civil society introduced.
7. Monitoring /transparency: MS and the EC should publish the annual implementation reports.
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