Migration governance externalization (MGE) in the EU: what it means and what it brings

Notes Internacionals CIDOB_327
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Data de publicació: 12/2025
Autor:
Francesco Pasetti, Research Fellow, CIDOB and Francesca Lupi, Researcher, CIDOB
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Migration governance externalization (MGE) has become the dominant approach in European Union (EU) migration politics and policy. 

This expansion is both quantitative – more actors, resources, and policy tools involved – and qualitative, through redesigned funding frameworks and deeper EU institutional involvement alongside member states. 

And it has magnified MGE’s key limitations – fragmented governance, opaque practices, and weak oversight – raising questions about the viability of this strategy and the legitimacy of EU action in migration governance. 

Externalization is the dominant approach in today’s migration governance. The outsourcing of migration control to origin and transit states has become the primary policy option for receiving countries, their silver bullet, a seemingly effective solution to reduce irregular arrivals, bring about effective returns, and ensure border control. Migration governance externalization (henceforth MGE) reflects a broad trend in Western democracies. In Europe, examples abound in recent years: the EU-Turkey Statement (2016), Italy’s Memorandum of Understanding (MoU) with Albania for offshore asylum processing (2023), partnerships with origin and transit country for returns foreseen in the New Pact on Migration and Asylum (2024) to name just a few that have sparked most debate. This demonstrates the centrality of this approach to the EU’s migration governance. But it is a mode of governing migration that transcends the European context. The cooperation between the US and Mexico under the Migrant Protection Protocols (controversially known as the “Remain in Mexico” policy) is a prime example. Although this specific agreement was repealed under the Biden administration, the process of migration outsourcing has continued in the United States, as confirmed by migrant returns deals with Ghana, Eswatini, Rwanda, and South Sudan in 2025.

The significance of MGE extends well beyond its role as a policy instrument; it is intrinsically linked to the centrality of migration in the EU’s political debate and democratic processes. In recent years, immigration has become one of the foremost concerns of EU citizens, polarizing public and political discourse, and playing a key role in electoral outcomes (Krastev and Leonard, 2024). Recent national campaigns and election results – such as those in France and Germany – together with the European Parliament elections of 2024, leave little doubt about this trend. The political centrality of migration is reflected in party strategies, where migration measures occupy a crucial space in program agendas. At the core of these programs lie MGE proposals. Exceptions to this trend are rare: only a handful of parties omit or reject externalization measures in their migration agendas. In short, navigating today’s polarized debate on migration and making sense of current migration affairs inevitably requires a clear understanding and proper contextualization of MGE.

Yet achieving this clarity is far from simple. First, academic literature has not reached a consensus on a shared definition of MGE: conceptual boundaries remain blurred and vary across studies, despite a growing body of research on the topic (e.g., Pariat, 2025Rausis and Lavenex, 2024). Second, the empirical reality is increasingly heterogeneous and complex. Externalization practices involve multiple actors, layers, geographies, and instruments – from readmission agreements and offshore asylum processing to informal deals, strategic partnerships, and deterrence campaigns – making it difficult to fully grasp the phenomenon.

This article tackles these challenges through three decisive contributions. First, we advance conceptual clarity by proposing an operational definition of MGE and unpacking its core dimensions. Second, we use this framework to map and analyze the main trends shaping externalization practices within EU migration governance. Finally, we assess the implications of these trends, highlighting the critical issues MGE poses for the future of European migration policy.

Conceptualizing migration governance externalization

When we talk about externalization in the field of migration, it is hard to find two experts who use the same definition and, more broadly, share the same understanding of the matter. The presence of multiple terms employed by scholars and practitioners says a great deal in this regard: “border externalization,” “external dimension of migration policy,” “outsourcing of migration control” are just some of the most common. These are not merely lexical differences, but also semantic ones, typically shaped by a disciplinary perspective, analytical lens, and the concrete measures under scrutiny.

Monique Pariat (2025), for instance, emphasizing formal agreements and legal obligations, describes externalization as a broad set of policies whereby destination countries seek to transfer part, or all, the management of migration flows outside their borders – typically through cooperation with third countries and international organizations. Cobarrubias and Lemberg-Pedersen (2025), by contrast, approach “border externalization” through postcolonial and decolonial theory, expanding and deepening its conceptual boundaries across space and time, and revealing its underlying colonial logics. The literature also offers various taxonomic frameworks to categorize externalization practices. FitzGerald (2020) uses medieval metaphors – cages, domes, buffers, and barbicans – to illustrate the architecture of repulsion that states have erected to control the movement of unwanted asylum seekers. More recently, Rausis and Lavenex (2024) proposed a taxonomy that identifies four overlapping layers – territorial, legal, diplomatic, and mental – through which states exercise control and power over human mobility. While these examples offer illuminating insights, they also reflect the heterogeneity of perspectives that characterize the research on externalization in migration studies. 

To move toward a working definition, this paper draws on the main points of convergence identified in the literature but ultimately advances our own conceptualization of migration governance externalization. Specifically, we define MGE as the outsourcing of the governance of migration flows to origin and transit countries in exchange for resources and support. While our definition is informed by existing academic debates, it is deliberately broad and flexible, enabling conceptual alignment with other definitions in the literature. At the same time, it is distinct in its capacity to encompass the wide and complex array of governance arrangements that regulate international migration, from deterrence and containment measures at origin to return programs for migrants who have already arrived.

Crucially, our approach emphasizes a conceptual shift from “policy” to “governance.” The terminology employed aims to link the reflection on externalization to the concept of governance. Unlike policy or government, in fact, governance captures the increasingly complex, multi-actor, and multilevel nature of contemporary modes of governing. As central governments progressively delegate authority upward to supranational institutions and downward to local ones (including private entities), traditional hierarchical modes of governing are being replaced by dispersed, diverse, and contested ones (Newman, 2005). This shift is not merely semantic: it reflects a deeper analytical commitment to understanding externalization as a dynamic and fragmented field of action, shaped by overlapping jurisdictions, hybrid arrangements, and shifting power relations. The term “governance,” thus, is better suited to capture the structural and operational complexity of today’s externalization practices, which extend beyond state-centric control and involve a constellation of actors, institutions, and instruments operating across multiple spatial scales.

MGE is interpreted and problematized differently across disciplines, with each perspective foregrounding distinct sets of questions and concerns. From the perspective of international relations, MGE involves agreements that regulate cooperation between sovereign states, raising crucial questions about power relations and the geopolitical implications of such arrangements. From an economics standpoint, it represents a transactional exchange between parties – a quid pro quo – where migration control is traded for financial aid, political recognition, or other strategic incentives, raising questions of opportunity, efficiency, and value. In political theory, MGE involves state action beyond territorial sovereignty, raising concerns about legitimacy, accountability, and democratic control. From a legal perspective, it entails obligations among parties that may be formal or informal, often operating in legal gray areas that raise critical questions about compliance with national and international norms.

The concept of MGE is also – and inevitably – multidimensional. To grasp its complexity, we focus on six analytical dimensions that we believe are individually necessary and jointly sufficient to articulate it consistently with the definition provided, and to cover the variation of its practices.

  1. Expected Returns: what the outsourcing state aims to gain through externalization. Expected returns may include reduced irregular arrivals, enhanced border surveillance, facilitated returns, or the containment of refugees in transit regions. It reflects the strategic objectives that justify the externalization effort and the rationale behind delegating migration control beyond national borders.

  2. Offered Incentives: what is provided in exchange to the cooperating country. Incentives may include financial aid, development cooperation, political support, diplomatic recognition, visa facilitation, or trade and security agreements, among others. Incentives constitute the currency of the transactional logic underpinning externalization and shape the terms of cooperation.

  3. Responsibility: who signs and/or who funds the externalized measure. It distinguishes between national, multilateral, and supranational actors (such as EU institutions), and between single-state, multi-state, EU-funded, or mixed financial arrangements. This dimension clarifies the institutional and financial framework of cooperation and reveals the distribution of roles and burdens.

  4. Character: the legal nature and enforceability of the cooperation. It distinguishes between degrees of formality, whether the arrangement is formal (e.g., a treaty), or informal (e.g., a political declaration). And determines the respective implications for accountability, implementation, and transparency between parties.

  5. Control: the depth and degree of involvement of the externalizing actor, namely whether it is engaged in the formulation, implementation, evaluation, or full cycle of the externalized measures. This determines the degree of influence and oversight retained by the outsourcing state throughout the policy process.

  6. Structure: the architecture of actors involved, and the governance model applied. It identifies whether the cooperation follows a principal-agent model, involves international organizations (e.g., IOM, UNHCR), civil society, and/or private contractors. This dimension captures the complexity of actor constellations and accountability chains and reflects the multilevel and multi-actor nature of governance structure underlying externalization. 

Taken together, these dimensions provide an analytical framework for making sense of the complex, heterogeneous, and evolving landscape of MGE. Through this lens, it becomes possible to identify and critically assess the key trends that shape the EU context.

Key trends of migration governance externalization in the EU

MGE is not a recent development in the EU context. First outlined at the European Council of Tampere in the late 1990s, this approach gradually took shape during the first decade of the 21st century through the Seville Council Conclusions of 2002. It gained further traction in the years that followed, via the two iterations of the Global Approach to Migration and Mobility (GAMM) in 2005 and 2011. Milestones such as the Valletta Action Plan (2015), the EU Emergency Trust Fund for Africa (2015), the Partnership Framework with third countries (2016), and the EU-Turkey Statement (2016) exemplify this logic. In parallel, member states have pursued similar strategies, with EU-border countries playing a pioneering role. Spain signed its first bilateral agreements involving externalization measures with Morocco in 1992, which was subsequently expanded and updated, then followed by those with Mauritania (2003) and Senegal (2006) (the latter framed within the First Africa Plan). Similarly, Italy started its externalization cooperation with Albania in the late 1990s and went on to sign agreements with Tunisia, Libya, and Egypt between 1997 and 2002, and continuously expanded in subsequent years (e.g., Italy-Tunisia MoU, Italy-Libya MoU). While the externalization model has thus evolved over several decades, recent years have seen a marked intensification of this approach in the EU. 

1. The consolidation of the external funding architecture for MGE

The first and most prominent trend to point out is the consolidation of the external funding architecture for MGE. Firstly, in terms of financial sources allocated. A turning point in this process was the launch of the Neighbourhood, Development and International Cooperation Instrument (NDICI)–Global Europe. With an overall allocation of €79.5bn, NDICI finances several flagship externalization initiatives, including Strategic and Comprehensive Partnerships (SCPs) with Tunisia (€105m for 2023) and Egypt (€200m for 2024–2027), a Migration Specific Partnership with Mauritania (€210m for 2024), and broader regional cooperation with Lebanon and Jordan. It represents a substantial increase compared to its predecessor, the Development Cooperation Instrument (DCI), which allocated €344m to migration-related objectives for the 2014–2020 period.

Additionally, new geographically targeted funding channels have emerged to support MGE along key migration routes. Between 2021 and 2023, €580m were allocated to countries along the Central Mediterranean route, including €52m for Morocco’s national asylum strategy and €96m to Tunisia for border management. These initiatives are part of broader regional investments that have grown by over 50% in the last decade. Notably, sub-Saharan Africa now receives more than €30bn – equivalent to 37% of the entire NDICI budget – compared to just €800m allocated to the whole African continent under previous frameworks. Another prime example of this quantitative expansion is the sharp increase in resources allocated to Frontex, whose budget has risen from €767.84m (2007–2013) and €1.638bn (2014–2020) to €6.4bn for the 2021–2027 period.1

However, the consolidation of the EU’s external funding architecture goes beyond the sheer volume of financial allocations. It also reflects a structural transformation in the institutional design of funding instruments. Earlier mechanisms, such as the EU Emergency Trust Fund for Africa (EUTF), were reactive and fragmented, often created in response to crises. In contrast, NDICI–Global Europe represents a shift toward a more centralized, stable, and long-term financial framework, embedding externalization as a core and strategic component of EU migration governance. 

2. Expanding returns and incentives

The second trend reflects the parallel expansion of the first two dimensions of MGE: expected returns and offered incentives. In recent years, both the strategic objectives pursued through MGE and the range of incentives provided to cooperating countries by the EU and its member states have broadened significantly.

On the one hand, the logic of externalization has moved well beyond the traditional goal of border control, extending to other areas of migration governance. Among these, two particularly sensitive domains stand out: international protection and managing returns. The Italy–Albania MoU is a pioneering case of asylum externalization, relocating asylum procedures to a non-EU country as a deterrence mechanism. Similarly, the New Pact on Migration and Asylum introduces legislative reforms aimed at accelerating returns through the Safe Third Country Concept and the establishment of return hubs in third countries. These developments reflect a growing convergence among member states on the need to extend and intensify the scope of MGE beyond its original border control mandate.

On the other hand, this diversification of policy goals has been accompanied by a parallel expansion in the incentives offered to cooperating countries. Beyond financial assistance, the EU now embeds MGE within broader strategic partnerships that address geopolitical interests such as trade, energy, and macroeconomic stability, exemplified by the aforementioned SCPs. For instance, the EU–Egypt SCP promotes investments in border management, return and anti-smuggling measures, alongside increased political dialogue, fiscal stabilization policies to reduce borrowing costs, and a renovated free trade agreement. Similarly, the EU–Tunisia SCP links migration goals with domestic socioeconomic reforms related to macroeconomic stability, employment, trade, and renewable energy supplies.

3. Increasing EU direct responsibility 

Another key trend concerns the evolving configuration of responsibility in MGE. Traditionally, EU institutions have assumed a relatively indirect role, primarily acting as financial backers of externalization initiatives led and signed by individual member states. A notable example is the EUTF, which largely financed bilateral agreements between member states and third countries, without the EU itself appearing as a formal signatory (such as the Italy-Libya MoU of 2017 and in Spain-Morocco border cooperation). 

In recent years, however, this pattern has shifted toward a more direct and visible engagement by EU institutions. Increasingly, the EU co-signs externalization agreements alongside member states, thereby assuming a more explicit institutional responsibility. The Migration Specific Partnership with Mauritania, jointly signed by EU institutions and Spanish authorities, is a perfect example of this new configuration. This shift is facilitated through instruments such as the Team Europe Initiatives, which promote coordinated action and joint representation.

This growing responsibility is also reflected in the diversification of agreement formats in which the EU is involved. While bilateral arrangements remain central, the EU is strengthening its involvement in multilateral formats, such as the United Nation’s Global Compact for Migration and the Rabat and Khartoum Processes, which bring together multiple actors at both policy and operational levels. Together, these recent developments signal a strategic reconfiguration of the EU’s role, from a background funder to a central actor in the institutional and diplomatic architecture of MGE.

4. Persistent opacity in the nature of MGE’ s practice 

A fourth key trend in the recent evolution of MGE is the proliferation of both formal and informal instruments. While these categories differ in character – formal agreements such as treaties tend to be legally binding and subject to scrutiny, whereas informal tools like MoUs and SCPs are non-binding and typically negotiated outside legislative control – their practical implementation reveals a shared deficit: neither ensures transparency, legal guarantees, or effective oversight.

Despite expectations that formal instruments would offer stronger safeguards, evidence shows that they often fall short. Status agreements, such as those signed by Frontex with third countries, include immunity clauses that obstruct human rights assessments and limit the scope of transparent monitoring. Parliamentary scrutiny is frequently absent, and accountability mechanisms remain underdeveloped (O’Flaherty, 2025). Unsurprisingly, informal instruments fare no better. Political declarations and soft law arrangements – exemplified by the EU–Turkey Statement and the EU–Tunisia SCP – operate in legal gray areas. These tools, while expedient, circumvent standard legislative procedures and lack enforceable human rights safeguards. Their informality allows critical decisions to be made without public debate, judicial review, and systematic evaluation (Gkliati and Kilpatrick, 2025).

This blurring of formal and informal instruments reflects a deeper structural issue: the proliferation of agreements with ambiguous legal status has created an opaque governance environment where oversight mechanisms are weak or absent. As the number and complexity of MGE arrangements grows, so too does the challenge of ensuring transparency and legal guarantees. Migrants affected by these arrangements often face insurmountable barriers to seeking justice, especially when jurisdictional ambiguities prevent access to effective remedies.

5. Fragmented governance and limited control

The final trend concerns the growing disconnect between the complexity of MGE structure and the effectiveness of control mechanisms. Over time, MGE has shifted from traditional bilateral agreements, typically negotiated between two states, toward multi-actor, multilevel governance models. These new arrangements involve a constellation of stakeholders operating across the policy cycle: EU institutions, member states, third-country governments, international organizations (e.g., IOM, UNHCR), civil society actors, and private contractors. The proliferation of actors, however, has blurred lines of responsibility and accountability. The case of EU–Libya technical cooperation illustrates this challenge: migration control measures have involved the Italian government, Libyan authorities, militias, and even smuggling networks, making it exceedingly difficult to assign responsibility or ensure compliance with human rights obligations. Paradoxically, this fragmentation has occurred alongside a growing role for EU institutions. However, this expanded engagement has not been accompanied by a proportional enhancement of oversight mechanisms, as highlighted by recent studies (O’Flaherty, 2025).

An especially critical issue is the lack of systematic evaluation. Assessments of MGE implementation and impact are often absent, non-mandatory, or completed too late to inform future programming. This means that those who fund and sign externalization agreements are frequently unable to determine the efficacy of their actions and, moreover, the consequences they produce. The EU–Turkey Statement exemplifies this problem: despite its high political profile, the agreement bypassed standard legislative procedures and lacked robust mechanisms for monitoring and assessing its impact. Analysts have since questioned its effectiveness and raised concerns about its compliance with international protection standards (Mesnard et al., 2024). 

The proliferation of increasingly complex and articulated governance models, coupled with the lack of systematic evaluation and clear accountability frameworks, has revealed a persistent gap between the EU’s ambitious governance structure and its ability to exercise effective, accountable control.

The coming future of the EU in MGE

A clear picture is emerging: MGE is getting bigger, more structural, and increasingly central to the EU’s external action. The consolidation of its funding architecture, the expansion of its strategic objectives and incentives, the growing responsibility of EU institutions, and more complex and articulated governing structures all point to a model that is no longer peripheral but foundational to European migration governance. 

What is also clear is that MGE is getting more contradictory. Its quantitative and qualitative expansion, indeed, has come along with the intensification of inconsistencies that have long characterized it: lack of transparency, weak control, and insufficient accountability. The proliferation of multi-actor and multilevel MGE structures has obscured lines of accountability, making it more difficult to attribute responsibility and ensure compliance with human rights obligations. The proliferation of MGE agreements has occurred alongside opaque practices with weak or absent oversight mechanisms. The EU institutions' increasing responsibility in MGE has not been met with corresponding advances in effective control. Parliamentary scrutiny and systematic evaluation are often lacking, and the ambiguous legal status of many MGE instruments undermines the ability to ensure effective monitoring and ensure the protection of migrants’ rights.

All this raises critical issues for the coming future of the EU and its member states in migration governance. A first concern regards possible negative externalities deriving from the broadening of MGE into new sectors. Experience with development aid demonstrates that when cooperation has been subordinated to migration control objectives, the effectiveness of the assistance has been undermined, destabilizing local economies at origin, and resulting in increased human rights risks (de Haas, 2007). As MGE extends to new policy domains – such as trade or energy – there is a substantial risk that similar distortions and adverse outcomes proliferate here too. Second, the MGE expansion heightens the EU’s strategic vulnerability vis-à-vis the possible instrumentalization of migration. The Ceuta incident in May 2021, when Moroccan authorities allowed thousands of migrants to cross into the Spanish enclave of Ceuta, has demonstrated how the outsourcing of migration control enables third countries to instrumentalize migration for political or economic gain, exposing the EU and its member states to coercion, as well as diplomatic and domestic crisis (Pasetti, 2021). Finally, the legal and normative tensions surrounding MGE expansion strike at the heart of the EU’s legitimacy. Persistent deficiencies in transparency, control, and safeguards not only undermine the EU’s capacity to uphold international and European legal standards – especially regarding human rights and migrant protection – but also expose the EU to institutional conflict. The recent dispute between the Italian government and European courts over the Albania MoU exemplifies how externalization measures can trigger clashes between political and judicial authorities at both national and EU levels. As the New Pact on Migration and Asylum is implemented, particularly its externalization provisions, these tensions are likely to intensify, testing the EU’s ability to reconcile its political ambitions with its foundational principles. Ultimately, the MGE expansion risks deepening the fracture between the EU’s (professed) values and its actual practices, raising crucial questions about the very future and legitimacy of the EU.

Nota:

1- The proposed Global Europe Fund, part of the new Multiannual Financial Framework (MFF) would increase the NDICI–GE budget by 75%, reaching €200bn, and double Frontex’s budget to €11.9bn. 

E-ISSN: 2013-4428

DOI: https://doi.org/10.24241/NotesInt.2025/327/en

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