Request for 1 document: "Procedure on Managing Possible Dublin Cases"
Dear European Union Agency for Asylum,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting the document titled "Procedure on Managing Possible Dublin Cases," dated March or April 2024. This document was referenced in document 48.ELREC2_MthR_202408_Redacted, released in response to a previous access request.
Given the significant public interest in the implementation of the Dublin Regulation and the management of asylum procedures, I urge the EUAA to disclose this document in full, without redactions where possible. Transparency in these procedures is crucial for public understanding of EU asylum practices and their impact on affected individuals.
If full disclosure is not possible, I request that any redactions be strictly limited and justified, in line with the principle of proportionality under Regulation 1049/2001.
Yours faithfully,
Lydia Emmanouilidou
Dear Ms Emmanouilidou ,
Reference is made to your below correspondence dated 4^th March 2025 .
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which was registered under reference
number 005372 on 6^th February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 27^th March 2025. In case
this time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
5372 on 6^th March 2025 .
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire todays, 27^th March
2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out further
cross-departmental consultations, thoroughly reviewing the relevant
documents and making comprehensive assessments against Article 4 of
Regulation (EC) No 1049/2001. Such should enable us to duly process your
application in the most diligent manner, in accordance with the principle
of good administration.
In light of the above, the EUAA has decided to extend the time-limit by an
additional 15 working days in accordance with Article 7(3) of Regulation
(EC) No 1049/2001. The new time limit is due to expire on 22^nd April 2025
.
Nonetheless, the Agency strives to get back to you as swiftly as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 07 March 2025 11:20
To: [FOI #15640 email]
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: Re: access to documents request - Request for 1 document:
"Procedure on Managing Possible Dublin Cases" [#5372]
Dear Ms Emmanouilidou ,
Reference is made to your below correspondence dated 4^th March 2025 .
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which was registered under reference
number 005372 on 6^th February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 27^th March 2025. In case
this time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
European Union Agency for Asylum
Email: [5][EUAA request email]
Website: [6]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
5372 on 6 March 2025.
As per our email dated 27 March 2025, the Agency already extended the
statutory deadline by an additional 15 working days until 22 April 2025
(included).
However, we kindly ask for your understanding that said timeframe does not
appear to be realistic in this instance despite the Agency’s best efforts
and commitment to the principles of good administration and transparency.
While we apologise for the delay in handling your present application,
this is essentially due to the particularly broad, open-ended and complex
nature of one of your other recent applications, combined with a
significant overall upsurge in access to documents requests received by
the EUAA which has made it difficult for the Agency to react within the
deadlines.
Therefore, we would be grateful for your agreement for the EUAA to
continue processing your (initial) application in a diligent and
comprehensive manner, while aiming to revert to you in substance by 6 May
2025 the latest.
As regards the status of your application, please note that the Agency is
well underway in terms of processing it and has recently sent out external
consultations under Article 4(4) of Regulation (EC) No 1049/2001. The EUAA
hopes to receive a response thereto early next week. Should there be any
other developments in terms of expected timings, then we will naturally
keep you informed.
Thank you for your cooperation and do not hesitate to get back to us in
the meantime.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 27 March 2025 13:34
To: [FOI #15640 email]
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: RE: access to documents request - Request for 1 document:
"Procedure on Managing Possible Dublin Cases" [#5372]
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
5372 on 6^th March 2025 .
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire todays, 27^th March
2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out further
cross-departmental consultations, thoroughly reviewing the relevant
documents and making comprehensive assessments against Article 4 of
Regulation (EC) No 1049/2001. Such should enable us to duly process your
application in the most diligent manner, in accordance with the principle
of good administration.
In light of the above, the EUAA has decided to extend the time-limit by an
additional 15 working days in accordance with Article 7(3) of Regulation
(EC) No 1049/2001. The new time limit is due to expire on 22^nd April 2025
.
Nonetheless, the Agency strives to get back to you as swiftly as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[5][EUAA request email]>
Sent: 07 March 2025 11:20
To: [6][FOI #15640 email]
Cc: Public Access To Documents Mailbox <[7][EUAA request email]>
Subject: Re: access to documents request - Request for 1 document:
"Procedure on Managing Possible Dublin Cases" [#5372]
Dear Ms Emmanouilidou ,
Reference is made to your below correspondence dated 4^th March 2025 .
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which was registered under reference
number 005372 on 6^th February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 27^th March 2025. In case
this time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [8][EUAA request email]
Website: [9]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
European Union Agency for Asylum
Email: [10][EUAA request email]
Website: [11]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Public Access To Documents Mailbox,
Thank you for your reply of 22 April 2025 regarding request 5372. I appreciate your efforts to ensure a timely reply to my request.
That being said, the request concerns a single document, and I note that the deadline has already been extended once. Given the limited scope of the request, I do not understand the need for further delay. Could you please provide a rough estimate of when I can expect to receive the document?
I would hope to receive it within the next couple of weeks. If there is no progress within that timeframe, I will consider lodging a confirmatory application and complaint.
I look forward to your response.
Yours sincerely,
Lydia Emmanouilidou
Dear Ms Emmanouilidou,
Kindly find enclosed a letter from Ms Nina Gregori, Executive Director of
the EUAA, in response to your application for access to documents.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 22 April 2025 20:53
To: [FOI #15640 email]
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: RE: access to documents request - Request for 1 document:
"Procedure on Managing Possible Dublin Cases" [#5372]
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
5372 on 6 March 2025.
As per our email dated 27 March 2025, the Agency already extended the
statutory deadline by an additional 15 working days until 22 April 2025
(included).
However, we kindly ask for your understanding that said timeframe does not
appear to be realistic in this instance despite the Agency’s best efforts
and commitment to the principles of good administration and transparency.
While we apologise for the delay in handling your present application,
this is essentially due to the particularly broad, open-ended and complex
nature of one of your other recent applications, combined with a
significant overall upsurge in access to documents requests received by
the EUAA which has made it difficult for the Agency to react within the
deadlines.
Therefore, we would be grateful for your agreement for the EUAA to
continue processing your (initial) application in a diligent and
comprehensive manner, while aiming to revert to you in substance by 6 May
2025 the latest.
As regards the status of your application, please note that the Agency is
well underway in terms of processing it and has recently sent out external
consultations under Article 4(4) of Regulation (EC) No 1049/2001. The EUAA
hopes to receive a response thereto early next week. Should there be any
other developments in terms of expected timings, then we will naturally
keep you informed.
Thank you for your cooperation and do not hesitate to get back to us in
the meantime.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[5][EUAA request email]>
Sent: 27 March 2025 13:34
To: [6][FOI #15640 email]
Cc: Public Access To Documents Mailbox <[7][EUAA request email]>
Subject: RE: access to documents request - Request for 1 document:
"Procedure on Managing Possible Dublin Cases" [#5372]
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
5372 on 6^th March 2025 .
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire todays, 27^th March
2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out further
cross-departmental consultations, thoroughly reviewing the relevant
documents and making comprehensive assessments against Article 4 of
Regulation (EC) No 1049/2001. Such should enable us to duly process your
application in the most diligent manner, in accordance with the principle
of good administration.
In light of the above, the EUAA has decided to extend the time-limit by an
additional 15 working days in accordance with Article 7(3) of Regulation
(EC) No 1049/2001. The new time limit is due to expire on 22^nd April 2025
.
Nonetheless, the Agency strives to get back to you as swiftly as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [8][EUAA request email]
Website: [9]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[10][EUAA request email]>
Sent: 07 March 2025 11:20
To: [11][FOI #15640 email]
Cc: Public Access To Documents Mailbox <[12][EUAA request email]>
Subject: Re: access to documents request - Request for 1 document:
"Procedure on Managing Possible Dublin Cases" [#5372]
Dear Ms Emmanouilidou ,
Reference is made to your below correspondence dated 4^th March 2025 .
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which was registered under reference
number 005372 on 6^th February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 27^th March 2025. In case
this time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [13][EUAA request email]
Website: [14]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
European Union Agency for Asylum
Email: [15][EUAA request email]
Website: [16]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear European Union Agency for Asylum,
Thank you for your reply of 29 April 2025. I am writing to submit a confirmatory application under Article 7(2) of Regulation 1049/2001, following your decision to refuse access to the document requested under case No 005372 – registered on 6 March 2025.
I respectfully request that the EUAA reconsider its refusal of access to this document in full or in part, for the following reasons:
1)Overly broad application of Article 4(1)(a) – public security
The Agency asserts that disclosure would undermine public security by eroding trust with Greek authorities. However, no specific or concrete risk to public security is substantiated. The document concerns procedural guidelines for managing Dublin cases, a standard administrative function central to EU asylum law. Public security must not be interpreted so broadly as to shield basic operational procedures from democratic scrutiny.
2)Document’s relevance to the public interest
The document directly concerns the implementation of the Dublin Regulation, which has profound consequences for asylum seekers across the EU. There is sustained and well-documented public concern — including from courts and national watchdogs--about the fairness, legality, and coordination of Dublin procedures, especially in frontline states like Greece. This context weighs heavily in favor of disclosure, or at the very least, partial access.
3)Mischaracterization of the document’s nature
Although authored by RIS, the document was shared with the EUAA and cited in a redacted document (48.ELREC2_MthR_202408_Redacted) previously disclosed by the Agency. Once a third-party document is held and used by an EU institution for its own activities, as appears to be the case here, it becomes subject to Regulation 1049/2001. The EUAA cannot entirely defer responsibility to the originating authority.
4)Failure to apply the principle of proportionality
EU case law (egmHautala v Council, Case T-14/98) requires institutions to assess whether parts of a document can be disclosed. The EUAA claims to have assessed this, but offers no detail as to which sections were considered particularly sensitive. Even if operational sensitivities exist, administrative documents like this typically contain introductory or general content that could be disclosed without risk.
5)Lack of meaningful public interest test
The refusal letter does not appear to reflect a balancing exercise between the stated risks and the significant public interest in transparency over Dublin procedures. The application of Article 4(1)(a) should not be automatic where an abstract concern about institutional trust exists.
In view of the above, I request full or partial access to the document. If disclosure is again refused, I ask that the EUAA provide a more detailed justification, including a summary of the contents and reasoning behind the conclusion that no section is disclosable.
Thank you for your consideration.
Sincerely,
Lydia Emmanouilidou
Dear Ms Emmanouilidou,
Reference is made to your below correspondence dated 13 May 2025.
We hereby acknowledge receipt of your confirmatory application for access
to documents under Regulation (EC) No 1049/2001, which was registered
under reference number 005729 on 14 May 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 5 June 2025. In case this
time limit needs to be extended, you will be informed in due course.
Sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents
(confirmatory) under Regulation (EC) No 1049/2001, which was registered
under reference number 005729 on 14 May 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 5 June 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 27
June 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 14 May 2025 11:54
To: Lydia Emmanouilidou <[FOI #15640 email]>
Subject: RE: Internal review of access to documents request - Request for
1 document: "Procedure on Managing Possible Dublin Cases"
Dear Ms Emmanouilidou,
Reference is made to your below correspondence dated 13 May 2025.
We hereby acknowledge receipt of your confirmatory application for access
to documents under Regulation (EC) No 1049/2001, which was registered
under reference number 005729 on 14 May 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 5 June 2025. In case this
time limit needs to be extended, you will be informed in due course.
Sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Kindly find enclosed a letter from Ms Nina Gregori, Executive Director of
the EUAA, in response to your application for access to documents under
Regulation (EC) No 1049/2001 together with the disclosed document.
Sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 04 June 2025 11:55
To: Lydia Emmanouilidou <[FOI #15640 email]>
Subject: RE: Internal review of access to documents request - Request for
1 document: "Procedure on Managing Possible Dublin Cases"
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents
(confirmatory) under Regulation (EC) No 1049/2001, which was registered
under reference number 005729 on 14 May 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 5 June 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 27
June 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[5][EUAA request email]>
Sent: 14 May 2025 11:54
To: Lydia Emmanouilidou <[6][FOI #15640 email]>
Subject: RE: Internal review of access to documents request - Request for
1 document: "Procedure on Managing Possible Dublin Cases"
Dear Ms Emmanouilidou,
Reference is made to your below correspondence dated 13 May 2025.
We hereby acknowledge receipt of your confirmatory application for access
to documents under Regulation (EC) No 1049/2001, which was registered
under reference number 005729 on 14 May 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 5 June 2025. In case this
time limit needs to be extended, you will be informed in due course.
Sincerely,
European Union Agency for Asylum
Email: [7][EUAA request email]
Website: [8]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.