4.2. Ensuring applicants’ rights and obligations
Discussions around the Pact rules on legal counselling in the administrative procedure and free legal assistance and representation in the appeal procedure continued in 2025. The EUAA developed a Practical Guide on Free Legal Counselling to support Member States in designing their national systems. In addition, the Comparative Overview of Legal Assistance and Representation in the Asylum Procedure presents the main legislative and policy developments in 2025, and summarises the most significant changes brought by the APR.
Czechia had already adopted the relevant legal provisions so a major change to its current system was not required, while draft laws related to legal assistance were pending in Germany and Sweden.184 In 2025, legal aid became limited to the first appeal instance in Latvia and must be covered by the applicant for a second appeal. Major changes were announced to the Dutch legal aid system.185 Furthermore, funding to provide legal assistance was cut for the Dutch Refugee Council, which is expected to increase pressure on the Central Agency for the Reception of Asylum Seekers (COA) staff in reception centres.186 The budget for legal aid in general, including for asylum seekers, was cut in Norway.187 Similarly, ECRE reported reduced access to legal aid in a number of countries, often due to financial cuts.188
There were only a few developments with the provision of information, as asylum authorities focused on updating material for the entry into application on the Pact. For example, the Swedish SMA and the Maltese International Protection Agency launched new websites, while the Portuguese AIMA created multilingual Frequently Asked Questions (FAQs). In France, a legislative change allowed authorities to submit the asylum seekers’ guide to applicants electronically, instead of in hard copy.189 New information campaigns were launched on YouTube and WhatsApp, with dissuasive messages about Belgium’s strict asylum and migration policy, targeting applicants with small chances of protection, both in countries of origin and transit, in particular Cameroonian, Guinean and Afghan applicants in transit countries, and Moldovan applicants in the country of origin.190
Several countries launched tenders for interpretation services to reinforce their pool of interpreters in preparation to the Pact. The EUAA provided support with interpretation services through several of its operational plans, for example in Belgium,191 Cyprus,192 Greece,193 Ireland (for second instance),194 Malta195 and Romania.196 In order to reduce risks related to informal interpretation, people under 18 years were prohibited to act as interpreters in official communications with national authorities in all types of administrative procedures.197 The Finnish Immigration Service now requires all interpreters to complete an online training which provides a comprehensive overview of the requirements in asylum interviews and expectations for such interpreters.198
- 184
European Union Agency for Asylum (EUAA). (15 December 2025). Comparative Overview of Legal Assistance and Representation in the Asylum Procedure.
- 185
European Union Agency for Asylum (EUAA). (15 December 2025). Comparative Overview of Legal Assistance and Representation in the Asylum Procedure.
- 186
Dutch Council for Refugees | Vluchtelingen
- 187
Norwegian Organisation for Asylum Seekers | Norsk organisasjon for asylsøkere. (6 November 2025). Regjeringen svikter de svakeste – og vår felles rettssikkerhet [The government is failing the most vulnerable – and our shared legal safeguards].
- 188
European Council on Refugees and Exiles (ECRE). (2026). Input to the Asylum Report 2026.
- 189
Décret n° 2025-403 du 5 mai 2025 portant modification de l'article R. 521-16 du code de l'entrée et du séjour des étrangers et du droit d'asile [Decree No 2025-403 of 5 May 2025 amending Article R. 521-16 of the Code on the Entry and Residence of Foreigners and the Right to Asylum], 5 May 2025.
- 190
European Migration Network (EMN). (20 March 2025). Belgium launches social media campaigns to discourage asylum seekers from coming.
- 191
European Union Agency for Asylum (EUAA). (December 2024). Operational plan 2025-2026 agreed by the European Union Agency for Asylum and Belgium.
- 192
European Union Agency for Asylum (EUAA). (December 2024). Operational plan 2025-2026 agreed by the European Union Agency for Asylum and the Republic of Cyprus.
- 193
European Union Agency for Asylum (EUAA). Operational plan 2025-2026 agreed by the European Union Agency for Asylum and Greece Amendment 1.
- 194
European Union Agency for Asylum (EUAA). Operational plan 2025-2026 agreed by the European Union Agency for Asylum and Ireland.
- 195
European Union Agency for Asylum (EUAA). (December 2024). Operational plan 2025-2026 Agreed by the European Union Agency for Asylum and Malta.
- 196
European Union Agency for Asylum (EUAA). (December 2024). Operational plan 2025-2026 Agreed by the European Union Agency for Asylum and Romania.
- 197
Lov nr 469 af 14/05/2025 Lov om ændring af en række love på børne- og undervisningsområdet, socialområdet, det familieretlige område, skatteområdet, beskæftigelsesområdet, udlændinge- og integrationsområdet og ældreområdet (Forbud mod anvendelse af personer under 18 år som tolke m.v.) [Law No 469 of 14/05/2025 Law amending a number of laws in the areas of children and education, social security, family law, tax law, employment law, immigration and integration law and the elderly law (Prohibition against the use of persons under the age of 18 as interpreters, etc.)], 14 May 2025.
- 198
Finnish Immigration Service | Maahanmuuttovirasto. (6 February 2025). Maahanmuuttovirasto tukee turvapaikkaprosessin sujuvuutta vahvistamalla tulkkien ammattitaitoa [The Finnish Immigration Service supports the smoothness of the asylum process by strengthening interpreters’ professional skills].