Platform for International Cooperation on Undocumented Migrants (PICUM)

PICUM welcomes the Commission’s proposal on combatting violence against women and domestic violence. We welcome the recognition of the multifaceted and intersectional realities of gender-based violence and the strong focus on the provision of support services to victims.

PICUM is a network of 167 organisations that has worked for nearly twenty years to advance the rights and improve the situation of people who are undocumented across a variety of areas, including access to health care, access to justice, the rights of undocumented workers, labour migration, the rights of children, families and youth, as well as fundamental rights in the context of immigration detention and return.

Many victims and potential victims continue to face significant barriers to accessing their rights under the directive, particularly when undocumented. - People who have an irregular residence status are still in most cases unable to engage with the police to safely report experiences of abuse that may amount to trafficking, without risking immigration enforcement action.

PICUMs membership and expertise focuses on migrant workers in precarious and/ or irregular employment. PICUM members provide migrant workers with essential services including information, counselling, casework, legal advice, training, mediation and holistic supports to address peoples needs, as well as spaces for peer-to-peer support and organising.

The Platform for International Cooperation on Undocumented Migrants (PICUM) welcomes the opportunity to contribute to the European Commissions call for evidence for an action plan on the protection of children against crime. The attached submission argues that the action plan must explicitly apply to all children regardless of residence status.

The Platform for International Cooperation on Undocumented Migrants (PICUM) was founded in 2001 as an initiative of grassroots organisations. Since then, it has built a comprehensive evidence base regarding the gap between international human rights law and the policies and practices existing at national level.

With twenty-five years of evidence, experience and expertise on issues affecting undocumented migrants, PICUM promotes recognition of their fundamental rights, providing an essential link between local realities and the debates at the policy level. PICUM members are among the non-governmental organisations (NGOs) and trade unions that supports people facing abuse, violence and exploitation.

PICUM is a network of 164 organisations working to ensure fundamental rights and social justice for undocumented people in 31 countries, primarily based in Europe. Several PICUM members work on trafficking in human beings and provide direct support to victims of trafficking.

The Platform for International Cooperation on Undocumented Migrants (PICUM) is a network of 164 organisations working to ensure fundamental rights and social justice for undocumented people in 31 countries, primarily based in Europe. PICUM acknowledges the Commissions initiative to create a platform to facilitate labour migration to the EU.

The provisions in the directive aimed at protecting undocumented workers are important. We have been able to use provisions to achieve positive outcomes in a few countries, where efforts have been invested in implementation. However, the efficacy of these provisions is hugely undermined by implementation barriers.

PICUM is extremely concerned by the impact on the rule of law in the EU as well as on migrants’ fundamental rights of the Commission’s proposal for a Council Decision establishing provisional measures for the benefit of Latvia, Lithuania and Poland. We are alarmed by the procedure through which this file has been proposed, as well as the contents of the proposal.

The Return Sponsorship scheme The proposed “return sponsorship” scheme raises more questions than answers. Firstly, the unclear division of responsibilities between the “sponsoring” state and the “benefitting” state risks creating legal gaps in accountability as well as serious breaches of fundamental rights.

As the former UN Special rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance Tendayi Achiume has underscored, ethno-nationalism is an important driver and manifestation of racial discrimination in citizenship, nationality and immigration laws, policies and practices.