The New Pact on Migration and Asylum has been presented as a turning point in EU migration and asylum policy. After years of tension, it is meant to create a more predictable and balanced system: more extensive registration of asylum seekers, faster procedures at external borders, clearer responsibilities and an effective solidarity mechanism.

Member states have had two years to adapt legislation and ensure operational preparedness and funding. The rules start applying on 12 June. But member states are not ready. Some countries still face legal and operational gaps, including in IT systems, staffing, reception capacity, border facilities, screening procedures and responsibility transfers.

This circumstance, however, should not be a surprise. The reforms are complex, interdependent and being applied across asylum and reception systems facing different pre-Pact dynamics and pressures.

This makes the idea of an ‘implementation day’, when all rules begin to function smoothly, unrealistic from the start. The Pact is not a switch that can simply be flipped. The coming months should therefore be seen not as the conclusion of the transition phase, but as its continuation.

Yet, this does not make political risks any less real. Notably, uncertainty around implementation could reinforce the EU’s determination to invest in externalisation policies.

The next stress test: October 2026

Since not every element of the Pact will be operational on day one, the question then becomes if the EU and its member states will be able to close legislative, administrative and operational gaps and invest in infrastructure and human resources. This will be essential to preserve trust and show that the new system works better than the one it replaces.

Contrary to some claims, the Pact does not completely overhaul the European asylum system but reinforces much of its existing logic. Instead, its most consequential innovation, alongside interdependence, is its new governance and implementation cycle.

The Pact introduces annual assessments, regular reporting, solidarity cycles, monitoring and a more structured role for the Commission. In principle, this should move EU migration policy from emotion to pragmatism, and from crisis-management towards a more resilient system.

This cycle should also make it possible to identify, and close remaining shortcomings identified. This makes October 2026 potentially more important than 12 June.

By then, the next annual migration report and solidarity cycle should give a clearer picture of whether the Pact is beginning to work. The first evidence on implementation will have emerged. Member states will have had some time to address the most urgent challenges. It will also be clearer whether responsibility transfers have resumed and whether solidarity pledges are meaningful enough to support countries under pressure.

Navigating the Pact’s interdependence

This is where the Pact’s interdependence, its second main innovation, could become its greatest vulnerability.

If a member state fails to register people properly in Eurodac, responsibility determination is affected. If screening is not carried out effectively, people may not be channelled into the appropriate procedure. If reception conditions remain inadequate, responsibility transfers may again be challenged before courts. If member states at the external borders are seen as failing to fulfil their responsibilities, others may become less willing to contribute to solidarity.

The danger in this context is that technical issues quickly become political disputes in the period until October of this year.

It may be hard to distinguish genuine difficulties from political reluctance to implement. A country may argue that it cannot comply because it lacks staff, infrastructure or legal clarity. Other governments conversely may suspect political reluctance. That distinction will shape whether the Pact is treated as a shared system under construction or an arena for shifting blame. If trust weakens, the system becomes more fragile. Member states that face secondary movements may again turn to unilateral measures, including internal border controls.

The first solidarity cycle adds another complication. It is shorter than the normal annual cycle, leaving limited time to deliver contributions and assess their impact before the next round begins. If support for eligible countries does not materialise quickly, they may have fewer incentives to make the investments needed to close remaining gaps.

The politics of perception: buying time with externalisation

If systematically applied, the Pact will bring significant practical changes.

For governments, the Pact could change the political narrative. How much ownership member states will show for rules they negotiated and adopted, however, remains to be seen.

The central political question is what changes for citizens. The Pact was justified as a response to public concerns. If people do not perceive any improvement, unmet expectations could be politically weaponised by far-right movements and deepen polarisation. This could weaken trust in the Common European Asylum System, amplify risks for Schengen, and even affect EU credibility as a whole.

The most likely short-term consequence of uncertainty around implementation readiness and the Pact’s effects is a continued push to keep irregular arrivals and asylum applications low.

The recently agreed reforms introducing return hubs, renewed efforts to launch migration partnerships and further externalisation measures match this logic. They offer governments a means to reduce irregular arrivals, increase returns and show visible action while the internal system is being tested. This trend is likely to accelerate rather than dissipate.

But there is a danger here too. At a time when implementation investment is still needed inside Europe, low arrivals and reduced pressure may create the illusion that the system is more resilient than it really is. The shifting of political attention and funding towards external arrangements could mean delaying the harder work of building a functioning CEAS.

That would be a strategic mistake. Externalisation may reduce pressure temporarily, but it cannot substitute implementation. If circumstances change, arrivals increase or third-country cooperation fails to deliver, the EU’s fragilities would re-emerge, despite the most comprehensive asylum reform in years.

Alberto Horst Neidhardt is a Senior Policy Analyst and Head of the European Diversity and Migration programme.

Virginie Jacob is a Senior Advisor on Migration and Diversity at the European Policy Centre

Helena Hahn is a Policy Analyst within the European Diversity and Migration programme.

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