Some Member States discussed or took measures to restrict the work of NGOs supporting migrants and refugees. In Greece, in August 2025, UNHCR and the National Commission for Human Rights issued a joint statement expressing concern over rhetoric undermining civil society working with refugees and migrants. In February 2026, a new ‘legal migration’ law was adopted that further restricts civil society’s activity. New provisions limit cooperation with NGOs registered in the National Registry of Greek and Foreign NGOs (Article 50) and introduce criminal liability for certain acts when committed by members of registered organisations (Article 15). In May 2025, Hungary proposed a bill titled ‘Transparency of Public Life bill’ targeting actors receiving foreign support without government authorisation, thus threatening civil society work, according to the NGO Transparency International. Poland reinstated an exclusion zone, restricting access for humanitarian actors to the Belarus border, limiting the ability of NGOs to provide assistance (Decree of the Minister of Interior of 2 December 2025). In late February 2026, Poland extended the buffer zone regime for 90 days, until early June 2026 (Decree of the Minister of Interior of Law no. 235).

National and European courts responded to some of these measures. In October 2025, the Cypriot Supreme Constitutional Court ruled that a past deregistration of the migrant-supporting NGO KISA was unlawful. In the 2025 case Ilareva and Others v. Bulgaria, the ECtHR ruled that Bulgaria had violated the rights of three NGO activists as it failed to protect them after they had received death threats due to their pro-migrant work.

Legal proceedings against individuals assisting migrants and refugees continued, most ending with acquittal but not all. In January 2026, according to a media article, the Appeal Court of the North Aegean (Greece) acquitted 24 volunteers from the NGO Emergency Response Centre International, accused of membership of a criminal organisation and of facilitating illegal entry, for their past volunteer rescue activities. In February 2026, the Greek authorities issued a European arrest warrant against the founder of the NGO Aegean Boat Report over allegations of human smuggling. In Poland, the District Court in Białystok (case no. III K 1787/24) dismissed the case concerning the volunteer Bartosz, charged in July 2025 with “influencing public officials” after assisting a Somali asylum seeker; and in September 2025 the Polish District Court in Bielsk Podlaski (case no. VII K 120/24) acquitted five activists, known as the “Hajnówka Five”, who had been prosecuted for providing food, cloths and shelter to a family of migrants. In contrast, a court in Rēzekne (Latvia) issued a decision against Ieva Raubiško, a member of the organisation “I Want to Help Refugees”, who assisted five Syrian asylum seekers at the Belarus border, for facilitating irregular border crossings, sentencing her to 200 hours of community service in August 2025. The Latvian authorities informed FRA in March 2026 that the judgement is not yet in force.

Echoing the United Nations Office on Drugs and Crime new interpretative guide (2025) on the Smuggling of Migrants Protocol, in December 2025, UN human rights experts called for a mandatory exemption from punishment of humanitarian assistance in EU law.

Civil society actors engaged in search and rescue at sea

In Italy, proceedings against humanitarian actors involved in search and rescue operations at sea continued, as documented in FRA’s update on search and rescue operations (2025). In July 2025, a coalition of 32 NGOs denounced the systematic obstruction of non-governmental SAR efforts, noting that their vessels had been detained multiple times under Italian law.

In 2025, judicial authorities in Sicily initiated criminal proceedings against six crew members of the Mediterranea Saving Humans vessel Mare Jonio for aiding irregular immigration, in a 2020 rescue operation involving 27 migrants transferred from the Danish tanker Maersk Etienne. In 2025, multiple NGOs had their assets detained or received fines: the aircraft Colibri 2 was grounded for 20 days and fined €100,000 in September; the ships Aurora, Nadir and Sea-Eye 5 were each detained for up to 20 days. In February 2026, Italian authorities detained the German NGO vessel Humanity 1 in Trapani and imposed a fine after a rescue operation.

At times, courts lifted the detention, as was the case by the Civil Court of Salerno, for example, of the GeoBarents. In February 2026, the Tribunal of Palermo ordered Italy to compensate an NGO for having blocked its rescue vessel in port in 2019.

In February 2025, the Italian Supreme Court of Cassation clarified that SAR responsibility includes organising disembarkation “within the shortest reasonably possible time” at a place of safety, and that considerations related to migration management cannot override these obligations. A few months later, in July 2025 the Italian Constitutional Court upheld the constitutionality of the legislative provisions regulating civil society SAR operations but clarified that their implementation must comply with international maritime law and fundamental rights, including the duty to render assistance to persons in distress at sea.

A report of the search and rescue organisation Sea-Watch, issued in October 2025 presents 54 violent incidents at sea by Libyan coast guards or Libyan militia over the past ten years, including two incidents in August and September 2025, when the coast guards shot at a civil society rescue boat.