This study constitutes a targeted substitute impact assessment of the Commission’s proposal for a revised Facilitation Directive. It highlights the misalignment of the proposal with relevant international and key EU law standards. It raises concerns about definitional issues, the lack of sufficient human rights safeguards, and the absence of a clear distinction between facilitation offences and the legitimate provision of services and humanitarian assistance. The study also examines the legality and proportionality of the proposed measures and stresses the need for a thorough evaluation of wider impacts on civic space and democracy at large.
https://www.europarl.europa.eu/thinktank/en/document/EPRS_STU(2025)765787, 5.3.25