2. Dublin 2.1. General Dublin statistics: 1 January – 31 December 2025 National data regarding requests in the Dublin procedure since 2021 are not available at the time of writing of the report. There were a total of 1,212 outgoing transfers carried out in 2025. 476 GCR does not currently have information regarding the practice of all Member States following the CJEU ruling in the Mengesteab case and CJEU judgment in C-47/17 and C-48/17, and GCR’s request for relevant information for 2023 from the MoMA was not answered. According to information provided by other organisations present in Greece, in 2024 German and Austrian authorities continued to consider that the time runs from the day of the informal request for asylum.477 The same applies for Germany during 2025.478 Based on GCR’s and other organisations’ experience, during 2022, as in previous years, there were specificities in the handling of cases based on the Member State the outgoing request is addressed to. Specifically, the Greek Dublin Unit submits all take charge requests within the three-month time limit foreseen in the Regulation.479 The time starts from the moment an application for international protection is officially registered with the Asylum Service. However, the German authorities, following the ruling of the CJEU in the Mengesteab case on 26 July 2017480 consider that the three-month time limit for sending a request to another country starts when the intention to apply for asylum is expressed; formal registration of the application with the Asylum Service is not required. To avoid rejection letters based on this argument, the Greek Dublin Unit tries to send the take charge requests within three-months from the expression of the intention to apply for asylum. 481 Regarding family reunification cases, if the Greek Dublin Unit is not informed within three months following the expression of the intention to apply for asylum, but is informed within three months from the registration of the asylum application, it sends the take charge request to the German authorities under the nondiscretionary Articles (8, 9, 10), this request will meet the time limit set out in the Regulation. Furthermore, some Member States’ interpretation of the CJEU judgment in the Joined Cases C-47/17 and C-48/17482 has resulted in rejections of requests. Following this judgment, the German Dublin Unit accepts only one re-examination request for each case and refuses to keep cases open even when further medical tests for the establishment of the family link are pending. The German Dublin Unit claims that there is no possibility to deviate from the deadlines of the Dublin III Regulation. The Netherlands, France, Sweden and the United Kingdom are among the Member States which have also followed the same practice rejecting cases on this ground. According to GCR’s knowledge, the German authorities continue to implement this judgment. NGOs noted that, during 2022, Swedish authorities also rejected cases on this ground. 476 477 478 479 480 481 482 It should be noted that Eurostat statistics related to the implementation of the Dublin III Regulation were last updated in July 2023 and cover the year 2022. According to Eurostat, the next planned statistical update is scheduled for July 2024 and should, presumably, cover the year 2023. See Eurostat, Statistics on countries responsible for asylum applications (Dublin Regulation), July 2023, available here. Information provided by NGOs, valid as of January 2025 Information provided to the author on a Dublin case ealy 2026 by the Dublin Unit case worker. Regulation (EU) No 604/2013 of the European Parliament and of the Council of 26 June 2013 establishing the criteria and mechanisms for determining the Member State responsible for examining an application for international protection lodged in one of the Member States by a third-country national or a stateless person (recast). CJEU, C-670/16, Tsegezab Mengesteab v Bundesrepublik Deutschland, Judgment of 26 July 2017, available at: https://bit.ly/3MXWEuK. Based on GCR’s observations from the field. CJEU, Joined Cases C-47/17 and C-48/17, X v. Staatssecretaris van Veiligheid en Justitie, Request for a preliminary ruling, Judgment of 13 November 2018, available at: https://bit.ly/2KpcqiA. 100

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