Member states were required to submit National Implementation Plans to the European Commission by the end of 2024 to clarify how these sweeping rules will function. Although 28 of the 30 participating countries have reportedly submitted their documents, only about half have made them accessible to the public. This information vacuum leaves humanitarian groups, including the International Rescue Committee, struggling to predict how the new protocols will impact vulnerable arrivals on the ground.
Italy serves as a stark case study in this lack of transparency. Despite a court order and repeated requests from civil society, the Italian government has withheld its full implementation plan. Instead, authorities issued a last-minute decree on 12 June outlining urgent compliance measures, yet the document lacks the granular detail required for effective oversight. This sudden shift leaves local actors and asylum seekers to navigate a system where procedures, particularly regarding the identification of torture survivors and minors, remain dangerously ambiguous.





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