On November 12^th and 13^th, 2025, Brussels was frenetic and buzzing with energy, due to the imminent extraordinary session of the European Parliament. One of the central topics was the Pact on Migration and Asylum, with the European Commission presenting its October Report on the Implementation of the Pact – delayed almost by a month. This took the form of the first annual Asylum and Migration Report, providing an overview of the migration and asylum scenario across the European Union as part of the newly launched first Annual Migration Management Cycle under the Pact. In addition to that, the Commission determined which States are under migratory pressure or currently at risk, and established new tools to support such States.

Latest Asylum and Migration data

The report included an analysis of the migration, asylum and reception situation between July 2024 and June 2025, which confirmed the data of the October EUAA 2025 Asylum Report.

According to the Commission’s Report, the data shows an improving migratory situation in the Union. Irregular border crossings fell by 35%, search-and-rescue disembarkations by 36%, and unauthorized movements within the EU by about 25%. Applications for international protection decreased by 21%, with a corresponding 20% drop in positive decisions. At the same time, Member States issued more return orders (+11%), largely linked to negative asylum decisions. However, the extent to which these reductions reflect durable structural changes rather than contingent effects (such as intensified cooperation with third countries or temporary deterrence measures) stays open to question.

Despite these apparently positive trends, enhancing the quality and resilience of the Schengen external borders remains essential, especially given rising security threats, and further efforts are needed to advance a common EU return system. While operational tools are very clearly defined, it remains unclear whether monitoring mechanisms for fundamental rights will be fully operational at the same pace as enforcement measures at the external borders.

Looking ahead, projections suggest that in 2026 irregular arrivals will further decrease across all major migratory routes, and the downward trend in asylum applications observed in 2024 and early 2025 is expected to continue. Nonetheless, one major gap remains: the need to improve contingency planning across Member States to ensure coordinated, rapid responses in the event of sudden shifts in migration pressures. This raises the issue of whether legal obligations on contingency planning are sufficient in the absence of operational capacity and political preparedness at national level.

States under migratory pressure

The central hub of the Commission’s report was the assessment of countries under migratory pressure, at risk of pressure or under a significant migratory situation. Based on the gathered data, the main countries declared to be under migratory pressures were Greece and Cyprus (due to high numbers of IBCs[1] and applications of for international protection), and Italy and Spain (due to disembarkations following a high number of SARs[2]), which are subject to “disproportionate obligations in relation to the overall situation in the Union”. Furthermore, twelve more countries (Belgium, Bulgaria, Germany, Estonia, Ireland, France, Croatia, Latvia, Lithuania, the Netherlands, Poland and Finland) are at risk of migratory pressures, and six more (Bulgaria, Czechia, Estonia, Croatia, Austria, and Poland) face significant migratory situations. A question here arises: how well does the current methodology separate the effects of actual exposure to migration from the impact of national policy decisions that might amplify pressure?

Implementation: challenges and improvements

As for the state of play of the Pact implementation, the Commission reports a “general need to speed up the pace” of reforms within Member States, despite significant improvements achieved at all levels. However, the focus on speeding up implementation brings concerns regarding the effectiveness of administrative or rights-compliant procedures under accelerated timelines.   

Challenges regarding the implementation of Eurodac, defining border procedures and screening arrangements, and organizational matters persist. To help face these issues, the Commission introduced a set of new instruments designed to balance responsibility and solidarity while streamlining asylum and migration management.

To enhance responsibility, several reforms are introduced to smooth procedures such as mandatory screening at external borders, accelerated asylum and return border procedures and a renewed Eurodac database. On the solidarity side, the Commission now uses the Annual Asylum and Migration Report to identify which Member States are under pressure or at risk, and to guide an implementing decision that triggers EU support – the goal being the creation of a permanent solidarity mechanism. This assessment feeds into the creation of the Annual Solidarity Pool, through which Member States contribute (via relocations, financial support, or material/technical assistance) to help the countries facing disproportionate obligations. To support States (especially of first entry), the Pact also establishes a Permanent EU Migration Support Toolbox, providing operational support, targeted funding, legal flexibility, and tools for returns, border management, and cooperation with third countries. Member States identified as under pressure gain access to the Solidarity Pool, while those at risk receive priority support from the Toolbox. Countries with a significant migratory situation will be able to request from the Council of the European Union a partial or full deduction from their solidarity contribution in the following year.

A key challenge will be ensuring that heightened reliance on EU-level operational support does not replace long-term national capacity-building.

What Now?

The coming months will be crucial to turn the Pact into a system that truly works in practice, not just on paper. Completing the three legislative proposals in the Parliament (the EU-wide list of safe countries of origin, updated rules on “safe third countries”, and a coordinated European system for returns) would be the final step to complete Pact’s framework. From there, the real test begins: turning this framework into action through shared responsibilities, predictable rules, and an integrated approach that balances security, fundamental rights and long-term planning. The foundations seem to be in place; what comes next will determine whether the Pact can deliver stable, coherent and sustainable migration management across the Union. The critical test will be if this framework can withstand sudden surges in arrivals without falling back on ad-hoc crisis management or selective compliance by Member States.

SOURCE: European Commission, Communication from the Commission to the European Parliament and the Council – The European Annual Asylum and Migration Report (2025), COM(2025) 795 final

[1] Illegal Border Crossings

[2] Search And Rescue operations