The Coalition on the EU Migration Pact, composed of 10 civil society organisations, has published an in-depth analysis of the general scheme of the International Protection Bill 2025, which will replace the International Protection Act 2015 and transpose the Pact texts into Irish law.

The coalition has expressed deep concern about the potential impact on people seeking protection in Ireland, and highlighted critical omissions in the government’s proposal on how it intends to proceed on a number of fundamental issues. 

The coalition’s concerns include the lack of clarity on whether applicants will retain their basic right to legal counsel; potential severe limits on freedom of movement or widespread use of detention;  whether the new accelerated procedure will ensure a fair and just system that accounts for vulnerabilities; and the removal of in-person appeals apart from a small minority of cases.

Nick Henderson, CEO of the Irish Refugee Council, said: “The Irish government is advancing major legislation that will drastically change and affect the rights of people seeking protection, transposing into Irish law more than 1,000 pages of EU Pact texts.

“We have grave concerns about both the content of the bill and the process behind it.

“The heads of bill contain crucial omissions. It is silent on reception conditions, legal counselling and age assessment and removes in-person appeals — crucial pillars of the protection process.

“The bill also fails to transpose key safeguards contained in the Pact texts, and in several areas takes a more restrictive approach where less restrictive options are available.

“The pre-legislative scrutiny process, due to take place in October, will be deficient if significant parts of the bill only emerge later, it will severely undermine meaningful pre-legislative scrutiny.

“We are urging the Department of Justice to publish an updated heads of bills urgently and to meaningfully engage with civil society and other stakeholders, ensuring sufficient time for consultation and feedback.”

Fiona Hurley, CEO of Nasc, the Migrant and Refugee Rights Centre in Cork, said: “This legislation marks one of the most significant shifts in asylum law in the history of the State.

“It risks dismantling key human rights protections, including fair procedures and meaningful access to asylum.

“It will turn Ireland’s asylum system into one that prioritises speed and enforcement over fairness and human rights.

“It normalises the erosion of human rights standards against some of the most vulnerable groups in our society.

“This should concern everyone who believes in fairness, accountability and the rule of law. The rights being limited here will not stop at the border.”