The five governments reached the understanding at a meeting in Copenhagen on Friday. They aim to conclude an agreement with a non-EU country by the end of 2026 and begin transfers in 2027.

The move shifts the proposal from political discussion toward planning for an operational system.

Proposed hubs would be located outside EU

Under the model, people who receive final return decisions could be transferred to facilities in a third country outside the EU.

The Council of the European Union and European Parliament agreed earlier in 2026 on rules that allow member states to establish such return hubs. The facilities could serve as a final destination or as a transfer point before a person moves to another country.

The framework requires agreements with host countries to comply with international human-rights standards and the principle of non-refoulement.

Host country has not been chosen

The five governments have not identified a final host country for the proposed hub.

African countries have emerged as potential partners, with Rwanda among the countries mentioned in reporting about possible arrangements. However, negotiations remain at an early stage, and no agreement with a host government has been announced.

The participating countries want technical talks to move quickly enough to support an agreement by the end of 2026.

EU rules establish the legal framework

The plan follows changes to the EU’s return policy agreed earlier this year.

The Council and European Parliament reached a provisional agreement in June on rules intended to make returns more effective for people without a legal right to remain in the bloc. The agreement includes provisions for return hubs in third countries while requiring safeguards for fundamental rights.

The rules form part of the wider implementation of the EU Migration and Asylum Pact.

Rejected asylum claims are at the center

The proposed hubs would apply to people who have already received return decisions. They would not cover people whose asylum applications remain under consideration.

That distinction separates the proposed system from the asylum process itself. The framework targets people who no longer have a legal right to remain in an EU member state.

The system is intended to support their eventual return to their country of origin or to another country willing to receive them.

Unaccompanied minors are excluded from the relevant return-hub arrangements under the agreed EU rules.

Governments seek faster returns

Governments backing the model argue that existing systems do not return enough people whose asylum or residency claims have been rejected.

The Council said its June agreement aims to make returns faster and more effective across the EU. The rules also strengthen cooperation between member states.

For Germany, Austria, Greece, Denmark and the Netherlands, the joint effort seeks to turn those legal provisions into an operational arrangement.

Rights protections remain a key issue

The proposed system is likely to face scrutiny over the treatment of people transferred outside the EU.

The EU framework requires agreements with third countries to respect international law and human-rights standards. This includes the principle of non-refoulement, which prohibits returning people to places where they could face persecution or serious harm.

The agreed rules also require arrangements to set out return procedures, conditions of stay and consequences if a host country breaches the agreement.

Earlier efforts provide a precedent

European governments have explored external arrangements for processing or transferring migrants for years, with varying outcomes.

The latest initiative comes after a long debate over whether countries outside the EU should play a larger role in Europe’s migration and return system.

Supporters argue that third-country arrangements could strengthen the enforcement of return decisions. Critics have raised questions about legal safeguards and whether countries outside the EU will accept people transferred under such agreements.

Five governments seek a joint approach

The participation of five governments could give the proposal greater political weight.

Germany, Austria, Greece, Denmark and the Netherlands face different migration pressures and operate under different national systems. All five, however, have an interest in increasing the number of people who leave the EU after receiving final return decisions.

A coordinated approach could also allow the countries to negotiate with potential host governments collectively.

Major hurdles remain

The agreement between the five countries does not mean a return hub is ready to receive people.

The governments must still identify a host country, negotiate an agreement and establish legal and operational conditions. Their current target is an agreement by the end of 2026, followed by transfers in 2027.

Financing, oversight, legal protections and arrangements for onward returns will also need to be resolved.

EU return policy moves toward implementation

The initiative adds to the EU’s broader effort to strengthen its return system.

The new framework gives member states a legal basis for establishing return facilities outside the bloc while requiring rights protections. The five-country initiative now seeks to determine how that framework can operate in practice.

Its success will depend on negotiations with third countries and on whether participating governments can resolve the legal, financial and humanitarian questions surrounding transfers.

Reporting Credit: Council of the European Union; European Parliament; governments of Denmark, Germany, Austria, Greece and the Netherlands.

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The case, filed Tuesday before the Community Court of Justice of the Economic Community of West African States (ECOWAS), is the latest legal challenge involving African countries that have signed third-country deportation agreements with the administration of U.S. President Donald Trump.

The coalition, which includes the Global Strategic Litigation Council, argues that Ghana accepted non-Ghanaian deportees from the United States before facilitating their return to countries where they allegedly faced persecution, despite existing legal protections.

Case Centers on 27 Deportees

The lawsuit represents 27 people among at least 60 individuals the United States has deported to Ghana since September 2025 under a bilateral agreement between the two governments.

According to the coalition, many of those deported had previously received protection orders from U.S. immigration judges preventing their removal to their countries of origin because of potential risks to their safety.

The legal filing alleges that after arriving in Ghana, most of the 27 individuals were transferred to their home countries within hours or days, despite informing Ghanaian authorities about those U.S. protections.

Some deportees also reported being shackled during flights from the United States.

After arriving in Ghana, they said they were detained under armed guard in military facilities, hotels and airport holding areas, often in difficult conditions while awaiting onward deportation.

Rights Lawyers Cite International Law

The coalition argues that Ghana violated the international principle of non-refoulement, which prohibits states from returning individuals to countries where they face persecution, torture or other serious harm.

Medical evaluations submitted with the lawsuit reportedly identified symptoms of post-traumatic stress disorder and severe depression among several of the deportees represented in the case.

The lawsuit asks the ECOWAS court to halt additional deportation transfers under the agreement, require Ghana to disclose the terms of its arrangement with the United States, award compensation to affected individuals and prohibit the country from entering similar agreements in the future.

A spokesperson for Ghana’s government did not immediately respond to requests for comment.

Growing Legal Challenges to U.S. Deportation Agreements

According to rights advocates, Ghana is one of at least nine African countries that have entered agreements with the United States to accept deportees who are not their own nationals.

Advocacy organizations say the Trump administration has deported thousands of migrants to nearly two dozen third countries under similar arrangements as part of broader immigration enforcement efforts.

Immigration lawyers argue that such agreements can serve as an indirect mechanism for returning asylum seekers to countries from which they were previously protected.

Earlier this month, another coalition of rights lawyers filed a separate legal challenge against Equatorial Guinea before the African Commission on Human and Peoples’ Rights, alleging that the country similarly returned U.S. deportees to their home countries in violation of international human rights obligations.

The Ghana case marks the first lawsuit brought under a 1979 ECOWAS treaty guaranteeing freedom of movement across West Africa, potentially setting an important legal precedent for future regional migration and human rights disputes.

Tags: Ghana, United States, ECOWAS, Global Strategic Litigation Council, Donald Trump, Deportation, Human Rights, Non-Refoulement, Immigration, Asylum Seekers, Equatorial Guinea, West Africa

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