Submission To European Border and Coast Guard

The European Network of Migrant Women is pleased to submit its contribution to update on EU Rules on European Border and Coast Guard. The planned revision of Regulation (EU) 2019/1896 on the European Border and Coast Guard (Frontex) will directly shape how power is exercised over women at borders, in hotspots, at sea, in detention and during return operations. A stronger Frontex that is not firmly anchored in women’s rights will mean stronger tools of harm against refugee and asylum-seeking women.

Our main concerns are:

Legal and operational grey zones in Frontex’s mandate, especially in cooperation with third countries, create spaces where male violence against women can flourish with limited accountability. Frontex’s current approach to data and situational awareness does not ensure systematic sex-disaggregated data and safe handling of information on sexual and male violence against women. Women’s disclosures about violence can be ignored or, worse, used against them in asylum and return procedures.
The push for more “effective” returns is built on a male-default understanding of migration. For women and girls, return often means being sent back to domestic abuse, honour violence, forced marriage, female-genital mutilation, trafficking and prostitution. Individual and sex-specific risk assessment are not guaranteed in practice.
Training and standards for border guards and Frontex staff are fragmented and frequently superficial on male violence against women, trafficking and trauma.
Governance and oversight remain structurally weaker than the operational drive for control and returns. The Fundamental Rights Officer and related mechanisms lack the mandate, resources and sex-specific expertise required to counterbalance a powerful and uniformed EU agency. Intersections with detention and holding practices are not clearly addressed in the Regulation.

We therefore call for the revision of the Regulation to centre migrant and refugee women and girls, and to make women’s rights a non-negotiable condition of any expansion or clarification of Frontex’s mandate. Any clarification or expansion on Frontex’s tasks must be explicitly conditional on Full compliance with EU fundamental rights and women’s human rights.

The Regulation should require that All data on border operations, incidents and returns are disaggregated by sex and age at minimum. Furthermore, the Regulation should make individual and sex-specific risk assessments mandatory before any return decision or operation.
We call for binding minimum standards for all border guards and Frontex staff, including the standing corps, covering Male violence against women and girls. Training must be Recurrent, practical and evaluated. The revision of the Regulation should Significantly strengthen the mandate, independence, staffing and budget of the Fundamental Rights Officer.

From a migrant-led feminist perspective, Frontex cannot simply be strengthened by adding more staff, more powers and more technology. A stronger Frontex without a strong, enforceable and sex-based women’s rights framework will intensify the violence and control that migrant and refugee women already face.