Grounds for detention

Legal changes through the Act on the Improvement of Removals

The Act on the Improvement of Removals was introduced by the coalition government in October 2023. It wasvoted through parliament on 18 January 2024 and entered into force on 27 February 2024. The reform involves changes in the legal framework for detention, among other reforms. More specifically:

• Asylum applicants can now be detained if grounds for detention apply at the time when they lodged their application. Before the reform, asylum seekers could only be detained in cases where they lodged the asylum request from within detention.[1] This is relevant notably for cases where persons file a subsequent application in order to avoid imminent removal.
• For pre-removal detention to be ordered, it is sufficient that the removal can take place within 6 months, instead of 3.[2]
• The grounds for pre-removal extension are extended to cases where persons entered legally, visa free or with a Schengen visa, and then overstayed their period for legal stay.[3]
• The maximum duration of custody pending removal increases from 10 days to 28 days.[4]
• The grounds for detention to enforce cooperation will be expanded, so that this form of detention can also be orders in cases of persons who do not cooperate in the establishment of their identity[5]
• Detainees who are not yet represented by a lawyer will be provided with a lawyer by the court[6]
• Minors and families will not be detained “in principle”, whereas previously they could be detained “only in exceptional cases and only for as long as it is adequate considering the well-being of the child.’[7]
• The new law foresees a possibility for authorities to file a complaint against the refusal by courts to order detention[8]

The Act also changes the authorities’ competences for enforcing removals:

• Exact timing of removals can no longer be announced, unless they involve families with children under 12 years of age.[9] Previously, the date of removals had to be announced to persons who had been holding a tolerated status for at least one year.
• In enforcing removals, authorities will be able to search not only the room of the person to be deported, but also other rooms in a reception centre.[10] It will also be easier for authorities to enter reception centres during the night to apprehend a person.[11]
• Search competences of the authorities are being extended to that the living space and personal belongings of persons can be searched in order to seize documents or electronic devices than can help establish their identity or nationality or to establish whether a removal is possible. In cases of ‘imminent danger’, a search no longer requires a court order.[12]

The reform also tightens rules around the enforcement of entry bans and extends possibilities for the expulsion of persons with a criminal conviction.[13]

According to the government, the aim of the reform was to facilitate the enforcement of removals by removing ‘obstacles’ amid rising numbers of asylum seekers. The government estimates that the reform will increase the number of returns by about 5%.[14] The reform was heavily criticised by NGOs for leading to a brutalisation of returns and for drastically reducing rights of non-nationals by heavily extending the grounds for detention, including for asylum seekers. In addition, stakeholders criticised that they were only given 2 days to comment on the proposals.[15] The Parliament Committee on Home Affairs and Community included some changes in the government’s draft, including the granting of a lawyer and the rule that minors and children are not to be detained in principle.

Legal situation in 2023

The legal situation as of 31 December 2023 is described below.

As of 31 December 2023, according to the law, there are two possibilities for the detention of asylum seekers whose application is still pending. The first relates to asylum applications which are lodged by people who are already in detention, in particular those:

• In pre-trial detention;
• In prison (following a conviction for a criminal or other offence); or
• In detention pending removal (Abschiebungshaft).[17]

An asylum application lodged after a foreigner has been detained for the purpose of removal does not always lead to release from detention, as detention is legally possible under certain circumstances. However, it has to be noted that detention pending removal, ordered solely on the grounds of illegal border crossing, is in itself not a sufficient reason to uphold such detention in case an asylum application is lodged. In addition, the authorities have to prove that there are further reasons for the prolongation of detention, such as a risk of absconding or an illegal stay for a duration of one month. The lodging of a subsequent or second application also does not preclude the ordering of detention unless the BAMF has decided to open another asylum procedure. [18]

The second possibility for detention during the asylum procedure was introduced in 2020 and relates to persons who are subject to an entry ban and present ‘a significant danger to their own or others’ lives, or to internal security’ or have been convicted for criminal offences, including asylum seekers (Section 62c Residence Act). According to the government, the provision is meant to allow for the detention of persons who are obliged to leave the country and who file an asylum application.[19] NGOs such as PRO ASYL and the Federal Association for Unaccompanied Minors heavily criticised the new provision as it contains no safeguards for vulnerable groups and lacks a proper legal basis in the grounds for detention as provided by the EU Reception Conditions Directive.[20]

If the lodging of an asylum application does not lead to release from detention, a detained person may be kept in detention until the BAMF has decided upon the case, but for a maximum of four weeks after the asylum request has been submitted to the BAMF.[21] Detention may even be upheld beyond that period if another country has been requested to admit or re-admit the foreigner on the basis of European law, i.e. the Dublin Regulation, or if the application for international protection has been rejected as inadmissible or as manifestly unfounded.[22]

Pre-removal detention (Abschiebungshaft) (including Dublin removal)

Legal situation in 2023

Pre-removal detention is ordered to secure removal to the country of origin or to a third country (usually in the form of a Dublin transfer). It can only be ordered for asylum seekers in the situations described above. The German Constitution provides that detention may only be ordered by a judge. The responsible authorities may only take a person into custody if there is reason to believe that this person is trying to abscond to avoid removal and if a judge cannot be requested to issue a detention order beforehand. In such cases, the detention order must be subsequently obtained from a court as soon as possible.

A judge may issue a detention order as ‘preparatory detention’ (Vorbereitungshaft) in cases of persons who have been expelled (usually following a criminal conviction) and in cases of persons who have been given a removal order on the grounds that they pose a risk to national security.[25] In most cases, however, a detention order is issued for the purpose of ‘securing the removal’ (Sicherungshaft). This type of detention is defined in Section 62(3) of the Residence Act.

This provision underwent a major amendment in August 2019 as part of the so-called Second Act for an improved enforcement of the obligation to leave the country (Zweites Gesetz zur besseren Durchsetzung der Ausreisepflicht, also known as the ‘Orderly Return Act’/Geordnete-Rückkehr-Gesetz). Section 62(3) of the Residence Act now states that a foreigner shall be placed in detention pending removal ‘if:[26]

• there is a risk of absconding;
• the foreigner is required to leave the country on account that they entered the territory unlawfully; or
• a removal order has been issued pursuant to Section 58a [against persons who have been expelled or who have been found to pose a risk to national security] but is not immediately enforceable’.

However, detention remains lawful only when removal cannot be ensured by other, less severe means.[27] Authorities have discretion to refrain from ordering detention if the person credibly demonstrates that they do not intend to evade the removal.[28] The detention order is unlawful in cases where it is clear that the removal cannot take place within 3 months for reason outside the control of the detained person.[29] This period was extended to six months for persons with a criminal conviction (unless the person is subjected to juvenile criminal law) with a reform that entered into force on 31 December 2022.[30] Further changes entered into force with the Act on the Improvement of Removals (see box above),

Risk of absconding

With the 2019 amendments, two new sub-paragraphs 62(3a) and 62(3b) Residence Act were introduced which contain an extensive definition of the grounds which may lead to the assumption of the risk of absconding (Fluchtgefahr). According to section 62(3a) a risk of absconding is to be assumed (as a refutable assumption), if:[31]

• the foreigner is providing the authorities with misleading information about their identity or has done so in connection with the planned removal or with possible impediments to removal and has not corrected false information on his/her own initiative, in particular by withholding or destroying documents or by claiming a false identity;
• the foreigner has been asked to remain at the disposal of the authorities at a certain place to carry out an official hearing or a medical examination and was not present at this place without good reason;
• the deadline set for leaving the country has expired and the foreigner has changed their place of residence without notifying the foreigners‘ authority of an address at which they can be reached, in spite of having been informed about his/her obligation to do so;
• the foreigner has been banned from (re-)entering Germany and has not been granted an exceptional permission to enter Germany in spite of such a ban;
• the foreigner has avoided removal in the past;
• the foreigner has expressly declared that they will resist removal.

Section 62(3b) of the Residence Act then defines ‘specific indications’ for a risk of absconding as follows:

• The foreigner has provided the authorities with misleading information about their identity in a manner which might result in an impediment to removal and has not corrected this piece of information on his/her own initiative, in particular by withholding or destroying documents or by claiming a false identity;
• The foreigner has paid substantial amounts of money, in particular to a third person [a smuggler or a trafficker] and it can be concluded under the individual circumstances that they will resist removal, because otherwise their expenditures would have been of no avail;
• The foreigner poses a significant risk to life and limb of third persons or to ‘significant legal interests of national security’;
• The foreigner has been sentenced repeatedly to at least one prison term for intentional criminal offenses;
• The foreigner has failed to obtain a passport or has refused or omitted to cooperate with authorities to fulfil other legal requirements for the clarification of his/her identity. The foreigner must have been informed in advance about the possibility of detention in case they did not comply with the aforementioned obligations;
• The foreigner has repeatedly failed to comply with an obligation imposed by the authorities to take up residence in a particular region or place [residence obligation] or with other obligations imposed by the authorities to secure and enforce the removal order;
• A foreigner who has entered the country legally but is now obliged to leave, cannot be apprehended by the authorities, because they do not have a place of residence at which they are predominantly staying.

It has been noted that the relationship between the newly introduced sub-paragraphs 62(3a) and 62(3b) Residence Act is not entirely clear.[32] The Explanatory Memorandum to the new Act states that the ‘indications’ listed in Section 62(3b) aim to define the more concrete grounds, whereas the ‘assumptions’ listed in Section 62(3a) ‘allow for a more reliable prognosis’ as to whether a person is trying to avoid removal.[33] This seems to imply that the ‘assumptions’ listed in sub-paragraph 3a are supposed to serve as additional grounds for detention, while the concrete evidence as listed in Section 3b would provide the basis for a possible detention order as ‘objective criteria’. However, the wording of the law does not support this interpretation: according to the law, a detention order can be based both on the ‘assumptions’ of sub-paragraph 3a and on the ‘indications’ of sub-paragraph 3b. The 2019 amendments therefore simply seem to have expanded the list of possible grounds for detention, rather than clarifying the preconditions for detention orders.

The new provisions have been criticised for their contradiction with the principle of detention as a ‘last resort’. Furthermore, it has been pointed out that the concept of a ‘refutable assumption’ as it is now set out in paragraph 3a is vaguely worded and places the full burden of proof on the individual who has to provide evidence that he/she is not trying to evade removal. Furthermore, Article 15 of the Return Directive (2008/115/EC) does not refer to the concept of a ‘refutable assumption’ as sufficient grounds for a detention order. For this reason, it is doubtful whether the amendments, in particular the concept of the ‘refutable assumption’ of sub-paragraph 3a are in line with the Return Directive.[34]

Detention in the context of the Dublin procedure

Section 2(14) of the Residence Act further contains special provisions for detention in the course of Dublin procedures (also referred to as Überstellungsgewahrsam/transfer detention). As a general rule, this section provides that most of the grounds for detention referred to above have to be regarded in the context of this provision as well: thus, the grounds listed in Section 62(3a) of the Residence Act shall apply accordingly to constitute a ‘refutable assumption for a risk of absconding within the meaning of Article 2 of the Dublin III Regulation.’ The grounds listed in Section 62 (3b) No. 1-5 of the Residence Act shall be regarded as objective criteria to assess a risk of absconding within the meaning of Article 2(n) of the Dublin III Regulation.

With the general reference to the ‘risk of absconding’ as defined in Section 62, the expansion of possible grounds for detention is now applicable to the transfer detention in Dublin cases as well. NGOs have raised doubts as regards the compliance of this provision with the Dublin III Regulation.[35] According to the latter, Member States may detain the person concerned only if there is a significant risk of absconding and on the basis of an individual assessment (Article 28 II of the Dublin III Regulation). In contrast, German law now lists numerous grounds for detention, some of which are vaguely worded thus raising the question as to whether they constitute significant reasons to assume a risk of absconding.

In addition, Section 2(14) of the Residence Act defines two other criteria for a ‘risk of absconding’:

• An asylum seeker has left another Dublin Member State before their asylum procedure (or Dublin procedure) had been concluded in this state and if there is no indication that they are going to return to the responsible Member State in the near future.
• An asylum seeker has repeatedly applied for asylum in another Dublin Member State (or several other Dublin Member States) and has left this state before the asylum procedure had been concluded.[36]

Through the introduction of another amendment in 2019, which is similar to an existing provision on detention pending removal, the authorities are now expressly given competence to temporarily detain people if there is a risk of absconding and if a court order cannot be obtained immediately. This can be regarded as providing a legal basis for what has been common practice. In these cases, authorities have to present the case to a court as soon as possible (Section 2 XIV 4th sentence of the Residence Act).

Custody pending departure (Ausreisegewahrsam)

According to Section 62b of the Residence Act, ‘custody pending departure’ can be carried out in the transit zones of airports or in other facilities ‘from where a direct departure is possible without having to cross a long distance to reach a border crossing point’.[38] This does not mean that this type of detention is limited to facilities close to airports, it is also frequently carried out in other detention facilities (see Place of detention). This form of detention is limited to a period of 10 days as of 2023 and shall apply in cases in which the deadline for leaving the country has expired and in which an immediate removal (i.e., a removal within the time-limit of 10 days) is feasible. The foreigner must further have ‘displayed a behaviour which leads one to assume that he/she will make the removal more difficult or impossible.’

An amendment which took effect in August 2019 as part of the Second Act for an improved enforcement of the obligation to leave the country (Zweites Gesetz zur besseren Durchsetzung der Ausreisepflicht, also known as the ‘Orderly Return Act’/Geordnete-Rückkehr-Gesetz) now further defines the grounds for this assumption. According to this provision, it is to be assumed that a foreigner is likely to obstruct removal measures, if:

• they violated their legal obligations to cooperate;
• they misled the authorities on their identity or nationality;
• they have been convicted of intentionally committing a criminal offence (with the exception of offences which are subject to a fine of up to 50 daily rates)
• they have exceeded the deadline allowed for voluntary departure by more than 30 days.’

Custody pending departure is subject to the same rules as the regular pre-removal detention procedure. A court order is therefore necessary and the detention can only be carried out in specialised facilities.[39] Between 2018 and 2021, custody pending departure was carried out in 10 out of 16 Federal States.[40]

Detention to enforce cooperation (Mitwirkungshaft)

The amendments introduced in 2019 through the ‘Orderly Return Act’ (Geordnete-Rückkehr-Gesetz) also established a new ground of detention to ‘enforce cooperation’ with the authorities (Mitwirkungshaft, Section 62 (6) Residence Act). This form of detention may only be applied in the following cases as of 2023 (for changes in 2024 see the box above):

• Failure to appear in person at the diplomatic mission or at a meeting with authorised officials of the foreigner’s assumed state of origin;
• Failure to appear in person for a medical examination for the purpose to establishing the foreigner’s ability to travel. 

The maximum period foreseen for this detention ground is 14 days and is subject to a court order, which means that the authorities may not carry out short-term arrests on the basis of this provision. There is no information or case-law available as to whether this ground for detention has been implemented since it entered into force in August 2019. In January 2020 media reports seemed to suggest that the new ‘detention to enforce cooperation’ had not been used yet,[42] but it was not entirely clear from these reports which type of detention they were referring to. Data from Germany’s largest detention facility in Büren (North Rhine Westphalia), for 2023, show that the instrument is used, but only comparatively rarely with 12 cases over the year 2023.[43]

De facto detention at the airport

Asylum seekers can be apprehended and de facto detained in the transit zone of an international airport. Although they are confined within the premises of a dedicated facility for the duration of the airport procedure, according to the Federal Constitutional Court, being held at the transit zone is not considered as detention in terms of the law.[44]

In practice, the applicant receives a decision of placement in the facility. For example, persons placed in the detention centre of Munich Airport receive a ‘notification of residence in the airport facility’ (Bescheinigung für den Aufenthalt in der Flughafenunterkunft) for the purpose of the airport procedure under Section 18a of the Asylum Act. This notification expressly states that this form of residence is not a freedom-restrictive measure. The fiction of non-entry into the territory is maintained, even if the person has been transferred to a hospital or to court. Police officers have to escort the person wherever they go outside the facility for the fiction to be maintained.[45]

[1] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 14; Section 14(3) Asylum Act.

[2] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 11; Section 62 (3) Residence Act.

[3] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 10, 46; Section 62 (3) Residence Act.

[4] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 11; Section 62b (1) Residence Act.

[5] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 11; Section 62 (6) Residence Act.

[6] Deutscher Bundestag, Recommendation for a resolution and report of the Committee on Home Affairs and Community (4th Committee) on the Federal Government’s draft bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 8; new Section 62d Residence Act.

[7] Deutscher Bundestag, Recommendation for a resolution and report of the Committee on Home Affairs and Community (4th Committee) on the Federal Government’s draft bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 7; Section 62(1) Residence Act.

[8] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 18; Section 62 Act on Proceedings in Family Matters and in Matters of Non-contentious Jurisdiction.

[9] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 10; Section 60a (5a) Residence Act.

[10] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 10; Section 58 (5) Residence Act.

[11] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 10; Section 58 (7) Residence Act.

[12] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 8; Section 48 (3) Residence Act.

[13] Deutscher Bundestag, Recommendation for a resolution and report of the Committee on Home Affairs and Community (4th Committee) on the Federal Government’s draft bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 6; Section 54 (1) Residence Act.

[14] Tagesschau.de, Wie Abschiebungen erleichtert werden sollen, 19 January 2024, available in German at: https://bit.ly/48tT2ts.

[15] GGUA Flüchtlingshilfe e.V., „Rückführungsverbesserungsgesetz“, 16 January 2024, available in German at: https://bit.ly/43NQk11; PRO ASYL, Kommentierung zum Entwurf eines Gesetzes zur Verbesserung der Rückführung, 13 October 2023, available in German at: https://bit.ly/3I91TWz; LTO, Bundestag beschließt “Rückführungsoffensive”, 18 January 2024, available in German at:

[16] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 14; Section 14(3) Asylum Act.

[17] Friederike Haberstroh, Detention and Alternatives to Detention. Study by the German National Contact Point for the European Migration Network (EMN). Working Paper 92 of the Research Centre of the Federal Office for Migration and Refugees, available at https://bit.ly/41IjHRv, 10.

[18] Sections 7(8), 71a(2) Asylum Act.

[19] Deutscher Bundestag, ‘Bundestag verschiebt Zensus in das Jahr 2022, 5 November 2020, available in German at: https://bit.ly/3H2nY6U.

[20] PRO ASYL, Stellungnahme zum Entwurf eines Gesetzes zur Einführung eines § 62c Aufenthaltsgesetz’, 16 July 2019, available in German at: https://bit.ly/3ItbtSy.

[21] Section 14(3) Asylum Act.

[22] Section 14(3) Asylum Act.

[23] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 11; Section 62 (3) Residence Act.

[24] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 10, 46; Section 62 (3) Residence Act.

[25] Section 62(2) Residence Act.

[26] Unofficial translation by the author, with minor abridgements.

[27] Section 62(1) Residence Act.

[28] Section 62(3) Residence Act.

[29] Section 62(3) Residence Act

[30] Section 62(3) Residence Act.

[31] Unofficial translation by the author, with abridgements.

[32] Stefan Keßler, Freiheitsentzug ad libitum? Die Auswirkungen des „Hau-Ab-Gesetzes II’ auf die Abschiebungshaft, in: Das Migrationspaket, Beilage zum Asylmagazin 8-9/2019, available in German at: https://bit.ly/3boa7HM, 44-54 (45).

[33] Explanatory memorandum to draft bill, Parliamentary document 19/10047, 10 May 2019, 39.

[34] PRO ASYL, Stellungnahme zum Entwurf eines Zweiten Gesetzes zur besseren Durchsetzung der Ausreisepflicht (BT-Drucksache 19/10047), 29 May 2019, available in German at: https://bit.ly/2WqrSlt, 16.

[35] Ibid., 5.

[36] PRO ASYL, Stellungnahme zum Entwurf eines Zweiten Gesetzes zur besseren Durchsetzung der Ausreisepflicht (BT-Drucksache 19/10047), 29 May 2019, available in German at: https://bit.ly/2WqrSlt, 5.

[37] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 11; Section 62b (1) Residence Act.

[38] Section 62b(2) Residence Act.

[39] Section 62b(3) Residence Act.

[40] Federal Government, Reply to parliamentary question by The Left, 19/31669, 4 August 2021, available in German at: https://bit.ly/4awfTGM.

[41] Federal Government, Draft Bill of the Act to Improve Removals (Entwurf eines Gesetzes zur Verbesserung der Rückführung (Rückführungsverbesserungsgesetz)), available in German at: https://bit.ly/49CaKMs, 11; Section 62 (6) Residence Act.

[42] br.de,Bericht: ‚Kein Bundesland nutzt ‘Geordnete-Rückkehr-Gesetz’‘, 3. January 2020.

[43] Ministry for Children, Youth, Family, Equality, Refugees and Integration of North Rhine Westphalia, „Sachstandsbericht Unterbringungseinrichtung für Ausreisepflichtige (UfA) in Büren“, quarterly report available on the website of the Federal State parliament: https://bit.ly/49r2hvD.

[44] Federal Constitutional Court, Decision of 14 May 1996, 2 BvR 1516/93. See also Federal Supreme Court, Decision V ZB 170/16, 16 March 2017, available in German at: http://bit.ly/2oRx9B4.

[45] See also: ECRE, Airport procedures in Germany: Gaps in quality and compliance with guarantees, May 2019, available at: https://bit.ly/2ZgTn2H.