Submission on the General Scheme of the International Protection Bill 2025 (2025)
Doras' Submission to the Justice Committee on Justice, Home Affairs and Migration on the General Scheme of the International Protection Bill 2025. The Bill will support the implementation of the EU Pact on migration and asylum at a national level in Ireland.
Doras welcomes the opportunity to comment on the General Scheme of the International Protection Bill 2025, which will support the implementation of the EU Pact on migration and asylum at a national level in Ireland. We note a number of positive developments as well as proposals to introduce new restrictive measures that may have the effect of limiting safeguards and protection for some of the most vulnerable in the international protection system.
Our submission deals primarily with the following issues:
- Screening process, including the impact of the screening process on vulnerable people
- Identifying vulnerable applicants and special reception needs
- Allocation, monitoring and standards of accommodation
- Powers to arrest, detain and restrict movement
- Family Reunification
EXECUTIVE SUMMARY
The key issues detailed in this document, and the corresponding heads, include the following:
- The power to “use reasonable force” and lack of safeguarding for vulnerable applicants during taking of biometric data (heads 7, 8).
- Lack of details or references to standards regarding accommodation including screening centres, accommodation centres and/or places of detention (heads 10, 45, 122, 129).
- Discretionary power to arrest and detain for a wide range of reasons including for the purpose of transfer to a screening centre and to verify identity and nationality, with limited oversight or safeguarding of vulnerable applicants (heads 12, 122).
- Lack of assurance and clarity regarding supports available to applicants (heads 15, 17, 19).
- Lack of provision for a full vulnerability assessment to identify special reception needs in compliance with obligations under article 25 of the recast Reception Conditions Directive 2024 (RCD 2024). In its current formulation, only a preliminary vulnerability check is provided for during the screening process (head 19).
- Limitations on the right to apply for family reunification visas (head 91).
- Special reception needs and family unity not taken into account when allocating accommodation, and no appeals mechanism provided for (head 118, 119).
