Overview of the main changes since the previous report update

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This report was previously updated in May 2024.

International protection

• Key Asylum Statistics: In 2024, 18,560 international protection applications were lodged.[1] The International Protection Office (IPO) issued a total of 13,099 decisions, 3,888 of which were positive.[2] Among these, 3,590 decisions granted international protection to applicants, while 298 granted humanitarian permission to remain[3] (see Statistics). The median processing time for cases processed to completion in 2024 was 18 months[4] under the ordinary procedure and 3 months under the accelerated procedure.[5] The average processing time for appeals before the International Protection Appeals Tribunal in 2024 was 10 months.[6] A total of 17, 751 personal interviews were scheduled by the IPO throughout the year[7] (see Regular procedure).

Asylum procedure

• EU Asylum and Migration Pact: On the 27^th March 2024, it was announced that the Minister for Justice, Helen McEntee TD, had secured government approval to seek the necessary agreement from the Houses of the Oireachtas (Houses of Parliament) to opt-in to measures in the EU Asylum and Migration Pact.[8] Subsequently, on the 30^th April 2024, the Irish Refugee Council appeared before the Oireachtas Justice Committee in order to make submissions regarding the Pact, expressing concern that the reforms contained within the Pact reflect an effort to limit access to the protection process for those seeking asylum in Ireland.[9] Ireland officially opted into the Pact on the 27^th June 2024, following a vote in both houses of the Oireachtas. While the Pact is legally in effect, Ireland, along with other EU countries, has until June 12, 2026, to fully implement the new regulations.[10] An implementation plan for the Pact was due to be produced in November 2024, however, at the time of updating, it remained unclear whether the implementation plan would be published or stakeholder feedback invited.[11]
• Processing of applications: The International Protection Office issued 13,099 decisions in 2024.[12] There was a total of 18,560 applications for international protection made throughout 2024.[13] According to latest available statistics, the number of international protection applications throughout 2024 has increased when compared with the previous reporting period (13, 276 applications throughout 2023)[14] (see Regular procedure).
• Length of procedure: Throughout 2024, the median processing time for first instance decisions was approximately 18 months for all cases decided pursuant to the ordinary procedure. This marks a slight increase in the overall processing time compared with the previous reporting period (13 months for all applications under the ordinary procedure).[15] The median processing time for cases decided pursuant to the accelerated procedure was 3 months throughout 2024.[16] However, processing times under the ordinary procedure remained lengthy in view of the commitment by the Department of Justice to reduce the overall processing time to 6 months in line with the recommendations of the Expert Advisory Group.[17] The median waiting period for appeals before the IPAT was 10 months[18] (see Regular procedure).
• Access to procedure: In January 2023, it was reported that the Irish Government were considering the introduction of ‘stronger border control measures’ in order to facilitate stricter immigration checks with regard to arriving passengers.[19] Throughout 2024, it was evident that these practices had been implemented, with an increase in reports of arrests and subsequent convictions for failure to produce a valid travel document upon request.[20] In response to a Parliamentary Question in November 2024, the Department of Justice stated that as of the 30^th of September 2024, there had been 132 charges made in respect of s.11 of the Immigration Act 2001 and 141 charges in respect of s.12 of the Immigration Act 2004.[21] There were also increased immigration checks at the border with Northern Ireland. In May 2024, it was announced that during a garda operation spanning a four-day period, 50 persons attempting to enter Ireland from the UK without the requisite visa or travel documentation.[22] While the Irish Refugee Council has not received any direct reports of persons being refused access to the international protection process on arrival in the State, it is nevertheless of significant concern that individuals may be refused leave to land or remanded in custody before any opportunity to seek protection arises (see Access to the procedure and registration).
• International protection appeals: The vast majority of appeals before the IPAT proceeded on a remote basis via audio-video link throughout 2024. In circumstances where an appeal was deemed unsuitable to proceed remotely, the appeal proceeded by way of an on-site oral hearing. This usually occurred in situations whereby to proceed with the appeal remotely would be contrary to the interests of justice or whereby the applicant requested an onsite oral hearing. Throughout 2024, the IPAT issued a total 2,887 appeal decisions.[23] Of these decisions, 676   applicants were granted refugee status, 80 were granted subsidiary protection status and the remaining 2,013 appeals were rejected on their merits.[24] 8,814 appeals were lodged to the Tribunal against negative first instance decisions by the IPO throughout 2024.[25] A further 21 appeals were submitted to the Tribunal pursuant to the European Communities (Reception Conditions) Regulations 2018.[26] The average median duration of the appeal procedure in 2024 was 10 months[27] (see Appeal).
• Accelerated procedure: On 8 November 2022, the International Protection Office introduced a revised international protection application procedure in accordance with the European Communities (International Protection Procedures) Regulations 2022. Under the revised procedure applicants from ‘designated safe countries of origin’ now receive a date for their substantive interview within four to six weeks of making their initial application. The accelerated procedure continued to operate throughout 2024 and was expanded to include additional categories of applicants. With effect from the 23^rd April 2024, the IPO began prioritising and accelerating the processing of applications from the country of origin with the highest number of applications in a given period.[28] From April 2024, applications from Nigerian nationals were prioritised.[29] In July 2024, the prioritisation process was reviewed and it was decided that the International Protection Office (IPO) would now prioritise cases from the two countries with the highest number of applicants in the last three months. Jordanian nationals were also subjected to the accelerated procedure from the 29^th July 2024.[30] At the time of updating, Nigerian and Jordanian applicants continued to be subject to the accelerated procedure. Additionally, throughout 2024, newly arrived single male protection applicants from ‘safe countries’ were not offered accommodation on arrival and in many cases were also subject to the accelerated procedure. In some cases, applicants who were street homeless were scheduled for their substantive interviews prior to having been offered accommodation by IPAS.[31] Interaction with such a complex legal process, without the provision of adequate legal advice, is extremely challenging and in the opinion of the Irish Refugee Council, it is completely inappropriate that an applicant be required to undertake a substantive interview while experiencing street homelessness. In January 2024, the Irish Refugee Council wrote to the International Protection Office requesting that applicants subject to the accelerated procedure and experiencing homelessness be given the option to postpone their protection application until such time as they are offered accommodation, however, in a subsequent response, the International Protection Office indicated that the option to pause one’s interview would not be considered on the basis to do so would be ‘detrimental to the interests of applicants’ and could result in further delay to the applicant’s application[32] (see Accelerated procedure).

• Updated list of ‘safe countries’ of origin: In June 2023, the Department of Justice announced that it was to conduct a review of the list of ‘designated safe countries of origin’, as established pursuant to the International Protection Act 2015 (Safe Countries of Origin) Order 2018.[33] Under Irish law, a country may be designated as ‘safe’ whereby it can be demonstrated that there is no persecution, torture or inhumane or degrading treatment or punishment and no threat by reason of indiscriminate violence in situations of international or armed conflict.[34] In January 2024, the Minister for Justice announced that, following the conclusion of the review process, two countries, Algeria and Botswana, would be added to the safe countries list.[35] Subsequently, in July 2024, following a further review, an additional five countries were added to the safe countries list. These countries include Brazil, Egypt, India, Malawi and Morocco, bringing to 15 the total number of countries appearing on the safe countries list[36] (see Safe country concepts).
• Designation of UK as ‘safe country’: The United Kingdom was previously designated a ‘safe country’ by the State in December 2020.[37] However, subsequently, in March 2024, a decision was issued by the High Court in the case of A v Minister for Justice, Ireland & Anor; B v International Protection Appeals Tribunal & Ors, in which it ruled that the legal basis for the designation was flawed as there was a gap between the legislation established in the International Protection Act and the EU legislation relevant to the case. Specifically, the national legislation failed to require that the Minister be satisfied that a person would not be subject to serious harm if returned to the United Kingdom, a requirement which is established pursuant to EU law.[38] The case was one of a number of cases taken by individuals seeking to challenge their return to the UK following the resumption of removals following the Covid-19 pandemic. Following the judgment, on 30^th April 2024, the Minister for Justice obtained Cabinet approval to progress legislative changes to allow the resumption of returns to the UK. Subsequently, in July 2024, the Courts, Civil Law, Criminal Law and Superannuation (Miscellaneous Provisions) Act 2024 was signed into law. The amended legislation includes a provision which revises the International Protection Act 2015 and requires consideration of serious harm to take place under the relevant sections of the Act.[39]
• Modernisation of International Protection Process: In July 2023, in response to the significant increase in international protection, and further to the recommendations established in the Catherine Day Report, the Department of Justice published a report on the international protection modernisation programme for 2023 and 2024. This programme was established with a view to enhancing efficiencies and throughput, as well as improving the application, interview and decision-making process for applicants.[40] As part of the reform strategy, in July 2024, a pilot was launched in which 50 international protection applicants were invited to conduct their s.35 interviews via Zoom. The pilot concluded in August 2024, and from January 2025, online interviews will be introduced on a phased basis for certain applicants.[41] The criteria for selection of online interviewees were not yet clear at the time of updating. However, according to the International Protection Office, the rationale for the introduction of online interviews was to increase processing capacity, as well as to reduce the need for applicants to travel to Dublin for the purposes of undertaking their interview.[42] Additionally, it was announced that from the 31^st July 2024, all single applicants applying for international protection would be registered and complete their international protection application digitally via an online portal. A similar procedure was introduced for families seeking international protection in November 2024.[43]
• Unaccompanied minors seeking international protection: In January 2024, it was reported that there had been, according to Tusla, the child and family agency, an ‘unprecedent increase’ in the number of unaccompanied children presenting to its Separated Children Seeking International Protection Service (SCSIP Service).[44] Subsequently, in April 2024, it was reported that Ireland has experienced a 500% increase in the number of unaccompanied children seeking international protection. According to figures released by Tusla’s Separated Children Seeking International Protection Team in April 2024, in the previous 15 months, 607 unaccompanied children were referred to the service. Of those, 243 minors arrived within the first 3 months of 2024.[45]  Separately, concerns were raised throughout 2024 regarding the use of unregulated Special Emergency Accommodation for unaccompanied minors in the care of the State. In February 2024, reports emerged that a care home utilised by Tusla had fabricated pre-employment checks of staff, including Garda vetting, therefore posing a significant risk to vulnerable children in its care. An internal report conducted by Tusla determined that Garda vetting files providing clearance for staff to work for the company running the care home had been altered, while pre-employment checks carried out in respect of prospective staff were reportedly falsified.[46] Concerns continued to be raised regarding the number of unaccompanied children seeking international protection missing from state care. In July 2024, it was reported that there were 39 children missing from State care. 22 of these children were unaccompanied minors seeking international protection[47] (see Age Assessment of Unaccompanied Minors).
• Response to war on Gaza: In October 2023, following the escalation of conflict in Gaza, the Irish Refugee Council wrote to the Taoiseach, the Minister for Justice and the Minister for Children Equality, Disability, Integration and Youth. In its correspondence, the Irish Refugee Council supported the call for a ceasefire and the free flow of humanitarian aid into Gaza. Additionally, IRC recommended that personal interviews in respect of international protection applicants from the Occupied Palestinian Territories be dispensed with where possible, that statutory-based and discretionary family reunification applications be expedited and that the establishment of a humanitarian admissions or resettlement scheme be considered.[48] Subsequently, in January 2024, the Department of Justice stated, in response to a Parliamentary Question, that it was working in conjunction with the Department of Foreign Affairs to ‘ensure a coordinated national response’ to the evolving situation in Gaza. This included ‘work to evacuate Irish citizens and their families’ from the region. Additionally, the Department of Justice stated that it is in regular contact with the Embassy of Ireland in Israel regarding a number of visa applications from residents of Gaza. According to the Department of Justice, the Embassy are actively engaging with applicants to gather the required documents so as to ensure that the Visa Division have everything required to progress such applications. It was also implied that no specific visa scheme or humanitarian programme would be established with a view to providing temporary Irish residence to persons affected by the ongoing offensive.[49] The Department of Justice’s stance with regard to Gaza continued throughout 2024[50] (see Differential treatment of specific nationals in the asylum procedure).
• Response to situation in Syria: Following the fall of the Assad regime, the International Protection Office announced that it was pausing final decisions with respect to international protection applications from Syrian nationals.[51] Following the announcement, the Irish Refugee Council was contacted by approximately 140 Syrian nationals seeking clarification regarding the current situation.[52] In a statement, the Irish Refugee Council queried the legal basis for the pausing of applications and further urged the International Protection Office to communicate to the 450 Syrian nationals currently in the protection process an approximate timeframe in which the issuing of decisions would resume.[53] Additionally, the Irish Human Rights and Equality Commission wrote to Minister for Justice, Helen McEntee, seeking clarification regarding the nature of the proposed pause in the issuing of decisions. The Commission expressed significant concern regarding the decision, stating that the situation in Syria remains ‘far from stable’ and that international protection applicants from Syria remain entitled to a decision on their status with due expedition[54] (see Differential treatment of specific nationals in the asylum procedure).

Reception conditions

• Reception capacity: Capacity within the Direct Provision accommodation system remained a significant challenge throughout the year. Throughout 2024, the number of individuals seeking international protection continued to increase. Accommodation capacity was thus, extremely constrained. On the 4^th of December 2023, the International Protection Accommodation Service announced that it would not be in a position to provide accommodation to all international protection applicants due to a severe shortage in accommodation capacity.[55] As a result, throughout 2024, all single male international protection applicants who presented to the International Protection Office were assessed by IPAS and HSE staff for any significant vulnerabilities or health issues and prioritised for accommodation as necessary. Whereby no significant vulnerabilities were identified, male applicants were not provided with accommodation.[56] This resulted in many applicants having no option but to sleep on the street for prolonged periods, often during bouts of inclement weather conditions and amidst a period of increased anti-immigrant sentiment.[57] At the time of updating, there were 3,062 individuals awaiting an offer of accommodation from IPAS. The Irish Refugee Council was aware of significant numbers of individuals experiencing street homelessness for a period of months.[58] Families with children and single women continued to be offered accommodation throughout 2024. IPAs who were not provided with accommodation received a temporary increase of €75 to their Daily Expense Allowance (DEA). This increased the allowance to €113.80 a week for eligible applicants.[59] Applicants were also advised that they could make an application for an Additional Needs Payment (ANP), to cover essential needs such as food, transport, or accommodation, however, in the experience of the Irish Refugee Council, the extent to which this was made available to applicants in practice remained inconsistent throughout 2024[60] (See Housing). Separately, a landmark judgment was delivered by the High Court on the 1^st August 2024 in the case of The Irish Human Rights and Equality Commission v. The Minister for Children, Equality, Disability, Integration and Youth of Ireland.[61] The proceedings were instigated by the Irish Human Rights and Equality Commission in accordance with their powers established pursuant to s. 41 of the Irish Human Rights and Equality Commission Act 2014.[62] Section 41 of the 2014 Act permits the Irish Human Rights and Equality Commission to seek relief of a declaratory or other nature in respect of any matter concerning the human rights of any person or class of persons and was the first time the Commission had utilised this legal power since its establishment. The legal action instigated by IHREC sought to compel the State to fulfil its legal obligations to provide for the basic needs of IP applicants, including the provision of shelter, food and access to basic hygiene facilities. It also seeks declarations from the Court that the failure to provide for the basic needs of IP applicants breaches the human rights of the people affected. Giving judgment, O’Donnell J. concluded: “applicants for international protection in the State have a well-established fundamental right to have their human dignity respected and protected, including by being provided with an adequate standard of living which guarantees their subsistence and protects their physical and mental health where they do not have sufficient means to provide for themselves.”^[63] The Court was thus satisfied that the State’s response to the needs of IP applicants who were acknowledged to be without accommodation was inadequate to the point that the rights of the class of person concerned were breached, having regard for Article 1 of the Charter of Fundamental Rights of the European Union. The Court further noted the CJEU’s judgments in Saciri and Haqbin, in which it concluded that a failure to provide for the basic needs of applicants amounts to a breach of their right to human dignity. Subsequently, in November 2024, it was announced that the State had lodged an appeal against the decision of the High Court. The appeal had yet to be heard at the time of updating.[64]
• Deterioration in reception standards: Throughout 2024, reception standards continued to deteriorate. 2024 continued to see a movement away from traditional use of hotel and guest house accommodation and an increased reliance by the State on so-called ‘emergency centres’ and tented accommodation. In March 2024, it was announced that the site of a former nursing home, located at Crooksling in southwest Dublin, would be repurposed for use as tented accommodation for male international protection applicants.[65] Following the opening of the site, many residents reported sub-standard living conditions which posed a risk to the health, personal safety, and wellbeing of individuals living at the facility. Initially it was believed that accommodation at the site would be offered as an alternative to street homelessness in respect of applicants who were not offered accommodation on arrival in the State. However, it subsequently became apparent that the site would be classified as ‘a designated accommodation centre’ for the purposes of granting material reception conditions. Many individuals would therefore spend indefinite periods at the site following periods of homelessness on arrival in the State. In July 2024, it emerged that a resident, accommodated at the site following a period of homelessness upon his arrival in the State, had instigated legal proceedings against the State, alleging that the facility does not meet his basic needs, as required by the Reception Conditions Directive 2013. The proceedings were ongoing at the time of updating.[66] The Irish Refugee Council visited the site in September 2024, during which residents also reported an apparent lack of governance and oversight within the facility, particularly regarding the needs of the residents, with no central manager present on site. The isolated location of the facility, as well as lack of public transport links also meant that residents had difficulty accessing employment in addition to basic services.[67] The levels of stress, anxiety and frustration amongst residents were also apparent, with many residents reporting a significant deterioration in their mental health since arriving at the facility.[68] There were also reports of harassment of residents at the site by far-right agitators, including verbal harassment and the flying of drones over the site in order to obtain aerial footage of same.[69] Similar tented facilities were established at Newtown Mount Kennedy, Co. Wicklow and Athlone, Co. Westmeath throughout 2024, bringing to six the total number of tented accommodation facilities in the State. Approximately 812 international protection applicants were accommodated at these facilities as of 15 December 2024.[70] Plans for an additional tented accommodation facility to be located at Thornton Hall, Co. Dublin were temporarily suspended on the 5^th of November 2024, after the State indicated its intention not to contest judicial review proceedings instigated in respect of the proposed development. The proceedings were instigated by local residents who alleged that a Ministerial Order made in respect of the site ought not be allowed to stand due to a lack of adequate environmental screening having been conducted in advance of establishment of the facility.[71] Subsequently, on the 18^th November 2024, it was reported that a revised Ministerial Order would be issued ‘within weeks’, however, development of the site remained suspended at the time of updating.[72] The proceedings followed several months of disruptive protests at the site by locals who objected to the development.[73] Throughout 2024, the State continued to rely on emergency centres comprised of disused offices, large conference rooms, schools, and sports halls in which to accommodate international protection applicants. Applicants were often accommodated in congregated and overcrowded settings without access to basic public services. Citywest Hotel and Convention Centre also continued to operate throughout the year as both a transit hub for the processing of beneficiaries of Temporary Protection, as well as for the accommodation of newly arrived international protection applicants. The Irish Refugee Council Information and Advocacy Service received several extremely concerning reports of alleged violence perpetrated by security officers working at Citywest against residents. Several residents sustained serious and life-altering injuries arising out of the alleged violence, while others had their reception conditions withdrawn and were rendered street homeless in purported acts of retribution perpetrated against residents for their involvement in such incidents.[74] As of the 15 January 2024, there were 407 international protection applicants resident in the centre[75] (see Conditions in Reception Facilities).
• Suspension of vulnerability assessment pilot project: Regulation 8 of the European Union (Reception Conditions) Regulations 2018 provides for the establishment of a vulnerability assessment process. Until January 2021 no standardised assessment was carried out in respect of vulnerable international protection applicants in Ireland, despite this being a clear requirement under EU law. At the end of January 2021, a pilot project to assess the vulnerability of applicants was established at Balseskin reception centre in Dublin.[76] The pilot scheme was subsequently extended to all newly arrived international protection applicants, as well as existing applicants, and aimed to determine whether the applicant has special reception needs arising from any vulnerabilities identified. On 8^th March 2024, IPAS announced that the pilot scheme would be suspended until further notice, citing ongoing demands on the Resident Welfare Team’s service due to the increased numbers of arrivals of protection applicants in the State as well as constraints on available accommodation across the IPAS portfolio.[77] This decision was communicated to all applicants who were queued for assessment, IPAS Centre Managers and NGOs, along with information on alternative supports.[78] From March – November 2024, it is understood that no vulnerability assessments were conducted, however, vulnerability triage in respect of newly arrived single male applicants continued.[79] In the interim, in April 2024, IPAS published a notice of request for tender with a view to outsourcing the vulnerability assessment process. Subsequently, in November 2024, it was announced that vulnerability assessments would resume and would be conducted by GoodPeople Homecare Ltd. According to IPAS, it is aimed to conduct 350 assessments a week, beginning with the existing backlog. Initially, vulnerability assessments were to be conducted at Citywest, with a view to expanding the service to the International Protection Office in the New Year.[80] As of November 2024, all newly arrived families seeking international protection were offered a vulnerability assessment. Additionally, as of May 2025, all those queued for assessment prior to the suspension had been assessed, with approximately 2,150 assessments having been conducted between November 2024 and May 2025[81] (see Identification of Vulnerable Applicants).
• HIQA Inspections of IPAS Accommodation: As of 9^th January 2024, the Health Information and Quality Authority (HIQA) assumed the responsibility for monitoring and inspecting International Protection Accommodations Service centres against the legally binding National Standards for Accommodation Offered to People in the Protection Process. This function is conferred upon HIQA by an amendment to the European Communities (Reception Conditions) Regulations 2018 by way of the European Communities (Reception Conditions) (Amendment) Regulations 2023 (S.I. No. 649 of 2023).[82] HIQA commenced inspections in early 2024, and in April 2024, published its first inspection reports.[83] As of November 2024, reports had been published in respect of nine centres. Three of the centres inspected were found to have no non-compliances identified against the National Standards. The remaining six had varying levels of compliance.  The areas of non-compliance identified included assessment and response to special needs of residents, contingency planning and preparedness, accommodation, food, catering and cooking facilities, governance, accountability and leadership, responsiveness of workforce and safeguarding and protection.[84] In one of the centres, inspectors found that a safeguarding incident involving the welfare of four children was not managed in line with national policy or guidance. Whereby non-compliance, providers were required to submit compliance plans in order to demonstrate what improvements they will make in order to bring the centre into compliance with the National Standards.[85]
• Comprehensive Accommodation Strategy for International Protection Applicants: On 27^th March 2024, it was announced that the Government had agreed a new Comprehensive Accommodation Strategy for International Protection applicants. Following the publication of the White Paper to End Direct Provision in 2021, significant increases in the numbers of those seeking international protection in the State, as well as the requirement to accommodate beneficiaries of temporary protection, have resulted in significant challenges to the State’s ability to provide accommodation in respect of those seeking international protection. A revised accommodation strategy was therefore published, both with a view to responding to the current homelessness crisis, as well as in order to establish a revised accommodation model, amending the approach outlined in the White Paper in order to take account of the increased number of arrivals.[86] The Strategy foresees a move away from full State reliance on private accommodation providers, and towards a core of State-owned accommodation. The State aims to deliver 14,000 state-owned beds by 2028, and this will be supplemented by commercial providers. In order to deal with the demand led nature of the system, the commissioning of emergency commercial accommodation will continue to be a feature in the short to medium term. According to the State it is the intention of the strategy to put an end to the use of unsuitable accommodation options currently relied upon and gain greater control in respect of the geographic distribution, allocation and dispersal of applicants.[87]
• Daily Expenses Allowance income assessment: In May 2024, the Department of Social Protection announced that an income assessment for the Daily Expenses Allowance, the social welfare payment for individuals in the international protection process, living in Direct Provision or who are awaiting accommodation in state-provided accommodation, would be introduced. The income assessment is applicable to individuals over the age of 18 years and will apply in respect of income from employment, self-employment and social welfare payments. If a person’s income is above €60 and below €125, their reduced rate of Daily Expenses Allowance will be based on their earnings. If a person’s income is €60 or less, their Daily Expenses Allowance payment will not be affected. The Daily Expense Allowance will cease whereby an individual has an income of more than €125 per week for a combined total of 12 weeks or more.[88] The income assessment was introduced from June 2024. At the time of updating, it was not clear the extent to which the assessment was enforced in practice.[89]

Content of international protection

• Increase in deportations: In October 2024, Minister for Justice Helen McEntee noted in a brief to cabinet that the number of deportation orders signed from January 2024 up to the 27^th of October 2024 was 1,792, an increase of approximately 140% on the same period in 2023. Additionally, in the same period, a total of 98 deportation orders were enforced, an increase of 165% compared with 2023. The number of voluntary returns also increased significantly from 175 in 2023 to 648 in 2024. Additionally, it was announced that a procurement process to secure charter flights was set to conclude at year-end, with a view to significantly increasing capacity to conduct further enforced deportations.[90]
• Changes to process for revocation of citizenship: On 23^rd of July 2024, changes were made to the process for revocation of citizenship for naturalised citizens in accordance with the Court, Civil Law, Criminal Law and Superannuation (Miscellaneous Provisions) Act 2024. These amendments follow a 2021 Supreme Court decision, Damache v. Minister for Justice, in which it was concluded that the current revocation process was unconstitutional as it was not sufficiently independent and lacked appropriate safeguards for those who were subject to revocation.[91] Previously, where an individual was informed of the Minister for Justice’s intention to revoke their certificate of naturalisation, they had a right to request a committee of inquiry to examine the decision. This committee reported the findings to the Minister, but the Minister was not obligated to accept the committee’s findings. On the basis that the Minister both proposed revocation and made the final decision regarding the revocation, the revocation process was found by the Supreme Court to be lacking an impartial and independent decision-maker. Under the new procedure outlined in the Act, where the Minister decides to revoke citizenship (following a procedure of informing the individual and receiving representations), an individual may seek a review by a committee of inquiry and the decision-making process of this committee will operate independently of the Minister. The committee will be able to affirm or reject the decision of the Minister.[92]

Case law summary:

The following notable decisions were issued by the Irish courts during the review period: 

• Citizenship – M v. Minister for Justice: This case concerned a South African national, who moved to Ireland in 2001. She subsequently applied for naturalisation in 2017, but her application was ultimately refused in 2022 due to not meeting the “good character” requirement pursuant to s.15 of the Irish Nationality and Citizenship Act 1956. This was based on several road traffic offences, including a conviction for careless driving. The applicant had been refused twice previously on similar grounds. The applicant sought judicial review of the decision to refuse her application, arguing that the refusal was irrational, disproportionate, and lacked sufficient reasons. The applicant also sought a declaration that only the Minister is expressly authorised to make a decision under s. 15 of the 1956 Act. On the first issue regarding fair procedures and the reasons given, O’Regan J., giving judgment, noted the ruling in Hussain v Minister for Justice[93], where it was held that there was no definitive interpretation of the words ‘good character’ in the context of naturalisation. Instead, meaning had to be derived from the statutory context and objectives of the legislation. She stated that as part of the naturalisation application, applicants were required to declare fidelity to the nation and loyalty to the State and, moreover, must be prepared to make a public commitment to discharge ordinary civic duties and responsibilities. Having regard to these requirements, it was not irrational for the Minister to view repeat offending, albeit over a protracted period of time, as being contrary to “good character.” On the second issue, O’Regan J referred to the Carltona principle, pursuant to which the Minister may delegate certain statutory powers to responsible officials. It was held that there is no express statutory provision to delimit the application of the principle in respect of section 15 decisions. The applicant’s appeal was thus unsuccessful.[94]
• Consideration of credibility in applications for international protection – J.R. (Algeria) v. International Protection Appeals Tribunal and the Minister for Justice: An Algerian national applied for international protection in Ireland, claiming that his uncle had threatened to kill him following a family dispute regarding property, and that his uncle held a powerful position in a terrorist organization. The applicant also alleged sexual assault by his uncle as a child. The International Protection Office (IPO) refused to grant refugee status or subsidiary protection, finding that the application was not credible due to lack of specificity and corroboration. The appeal to the International Protection Appeals Tribunal upheld the IPO’s decision. The applicant then sought judicial review of the decision in the High Court. Gearty J., giving judgment, concluded that that the Tribunal’s decision lacked clarity as to whether it accepted the applicant’s claim of death threats, and if it did, it had failed to consider the presumption of a real risk of harm under Section 28(6) of the International Protection Act 2015, which provides that if an applicant has suffered previous serious harm, that is a serious indication of a real risk of serious harm unless there are good reasons to consider that such harm will not be repeated. Gearty J. was critical the Tribunal for citing the applicant’s failure to mention sexual assault earlier as a credibility issue, given the difficulty of corroborating such claims. Finally, the Tribunal’s consideration that the lack of specificity in the applicant’s assertion that his uncle belonged to a terrorist organisation constituted a negative credibility factor was unexplained and appeared unnecessary. On this basis, it was held that there were no clear reasons provided in the Tribunal’s decision and on that basis, the decision of the Tribunal was quashed.^[95]
• Access to the Labour Market – A. (a minor suing by his mother and next friend, A.A.) & Ors v International Protection Appeals Tribunal & Ors: The first-named applicant was a child and his parents were the second and third-named applicants. The second and third-named applicants applied for international protection in Ireland prior to the first-named applicant’s birth. While their applications were being processed, the parents received labour market access permissions, but their protection applications were ultimately refused. Their right to access the labour market was terminated and they were issued with deportation orders prior to the child being born. After the child’s birth, the mother applied for international protection on his behalf. The parents then sought labour market access permission deriving from their child’s application, asserting that they possessed a vicarious right to work as parents of a minor applicant for international protection. These applications were rejected, and a subsequent appeal was also denied. The second and third-named applicants sought judicial review in the High Court, which ruled that the parents could not claim a derived right to labour market access by virtue of the child’s status as an international protection applicant. This decision was appealed to the Court of Appeal, who ultimately dismissed the appeal but clarified several important points. The Court held that, under the recast Reception Conditions Directive (2013/33/EU), a child has the right to access the labour market, but this is subject to the Protection of Young Persons (Employment) Act 1996, which requires permission for minors to work. It also clarified that the term “applicant” under the Directive does not extend to family members of international protection applicants. On whether the derived rights for parents established under the Zambrano case law applies, the Court of Appeal held that this related to EU rights in respect of an EU citizen child and the issues were therefore of an entirely different nature. The Court further concluded that while the child’s best interest were required to be considered, there was no evidence that the child’s best interests were harmed by the parents’ inability to access the labour market. The Court also addressed human dignity, stating it is a basis for rights but not a right in itself. The constitutional right to seek employment was distinguished from the NHV case, as the parents had not been deprived of a right when they themselves were applicants. The Court concluded that no preliminary reference to the EU Court of Justice was necessary, and the appeal was thus dismissed.[96]
• Application for protection and country of nationality – S.A. (Zimbabwe and South Africa) v. The Chief International Protection Officer: A Zimbabwean national applied for international protection in Ireland, but her application was refused on the grounds that the IPO (International Protection Office) believed she was South African and could safely return there. This conclusion was based on answers in her questionnaire, which she filled out three days after arriving in Ireland without legal advice. Later, after receiving legal advice, the applicant clarified her true nationality as Zimbabwean, submitting a passport, birth certificate, and a marriage certificate to corroborate her claim. In her section 35 interview, the applicant repeated that she was born in Zimbabwe and explained that she had used false South African identity documents to travel to Ireland. Despite this, the IPO recommended refusal of international protection. The decision was appealed to the High Court. Gearty J., giving judgment, ruled that the IPO had failed to correctly assess all the evidence submitted by the applicant. The Court found that the IPO incorrectly assumed the passport and birth certificate submitted by the applicant in support of her claim that she was a Zimbabwean national belonged to a different person due to the different name on the documents. When the supporting documentation was considered in its totality it was clear that all of the documents referred to the same individual, the applicant. Considering the errors which formed the basis for finding the applicant was South African, along with the timing of the applicant’s completion of her questionnaire, and the fact that the applicant had only received legal advice after she had offered misleading information, the High Court held that the decision that she was not Zimbabwean was reached on an incorrect basis. As the incorrect assumption as to the applicant’s nationality significantly impacted the application process, the High Court concluded that this was a material error. The case was remitted for reconsideration, with the High Court stating that any appeal hearing before the International Protection Appeals Tribunal (IPAT) would now be treated as a first-instance hearing due to the fundamental nature of the nationality issue.^[97]
• Reception conditions – Irish Human Rights and Equality Commission v Minister for Children, Equality, Disability, Integration and Youth & Anor: These proceedings were instigated by the Irish Human Rights and Equality Commission in accordance with their powers established pursuant to s. 41 of the Irish Human Rights and Equality Commission Act 2014. Section 41 of the 2014 Act permits the Irish Human Rights and Equality Commission to seek relief of a declaratory or other nature in respect of any matter concerning the human rights of any person or class of persons and was the first time the Commission had utilised this legal power since its establishment. The legal action instigated by IHREC sought to compel the State to fulfil its legal obligations to provide for the basic needs of IP applicants, including the provision of shelter, food and access to basic hygiene facilities. It also seeks declarations from the Court that the failure to provide for the basic needs of IP applicants breaches the human rights of the people affected. Giving judgment, O’Donnell J. concluded: “applicants for international protection in the State have a well-established fundamental right to have their human dignity respected and protected, including by being provided with an adequate standard of living which guarantees their subsistence and protects their physical and mental health where they do not have sufficient means to provide for themselves.” The Court was thus satisfied that the State’s response to the needs of IP applicants who were acknowledged to be without accommodation was inadequate to the point that the rights of the class of person concerned were breached, having regard for Article 1 of the Charter of Fundamental Rights of the European Union. The Court further noted the CJEU’s judgments in Saciri and Haqbin, in which it concluded that a failure to provide for the basic needs of applicants amounts to a breach of their right to human dignity. The High Court’s decision is currently under appeal.^[98]
• Labour market access – LK v International Protection Appeals Tribunal & Ors: The applicant was refused permission to access the labour market on the basis that the delay in issuing a decision on his international protection application was attributable to him. In the first instance, the applicant did not receive notification of his scheduled interview and therefore did not attend same. Through his social worker, an interview was subsequently arranged for the applicant. He received a questionnaire, for which he was granted four extensions of time, including for reasons relating to access to legal advice, COVID-19 and securing a translator. The applicant submitted his questionnaire almost a year after he made his initial application. In the High Court, Heslin J. quashed the decision and held that the applicant was entitled to Francovich damages. The International Protection Appeals Tribunal, the Minister for Justice and the Attorney General appealed the case to the Supreme Court. On reviewing the reasons for the delay in completing the questionnaire, the Supreme Court held that the applicant was not responsible for all of the delays, including the first delay in failing to be informed of a preliminary interview and there were good reasons for other delays, including the COVID-19 pandemic and difficulties with scheduling an appointment. However, there were insufficient reasons given for the overall lengthy delay in completing the questionnaire. The Supreme Court held that the trial judge erred in his approach to the question of delay on the part of the applicant. The question that then arose is how the various elements of delay in processing the application were to be attributed. The appellants had argued that the right is not absolute and the insertion of “attributed in part” was permitted due to the discretion afforded to Member States under the Directive. The Supreme Court found that where the delay can be attributed to both the applicant and the State, it was unclear as to how to weight the different periods of delay and it was further unclear as to whether attributed in part makes it difficult to exercise rights conferred by the EU legal order. The Supreme Court held that there was no clear answer to the case and decided to refer a preliminary reference to the CJEU.^[99]
• Inadmissibility – AAH & MAH v International Protection Appeals Tribunal: The applicants, both Somali nationals, had been granted international protection in Greece and then travelled to Ireland, where they applied for international protection. Their applications were deemed inadmissible under section 21(9) of the International Protection Act 2015. They challenged the inadmissibility decision, arguing that the conditions in Greece were so poor—leading to destitution, homelessness, and extreme poverty—that returning there would breach their fundamental rights under the ECHR and the Charter of Fundamental Rights. They also contested the lack of an oral hearing and the evidential burden in the decision-making process. The International Protection Appeals Tribunal (IPAT) upheld the IPO’s inadmissibility decision, and the applicants sought judicial review in the High Court, where their cases were joined as lead cases for a group of similar “Greek Transfer Cases”. Phelan J. in the High Court recalled the principle of mutual trust between EU Member States, which assumes that all beneficiaries of international protection are treated in accordance with EU law and human rights standards. She referenced the CJEU’s Ibrahim case[100], noting that applicants must prove a risk of serious harm if returned, with severe living conditions not being enough unless they involve inhuman or degrading treatment. The Court found that conditions in Greece did not rise to this level of severity. On the legality of section 21, Phelan J. found that it was compatible with EU law and did not lead to unlawful decision-making. Regarding the right to an oral hearing, she concluded that the applicants’ rights were sufficiently met through two preliminary interviews, which provided an adequate opportunity to present their case. No specific element of their case was identified that would require an oral hearing. One applicant also challenged section 21 on constitutional grounds. Phelan J. emphasised that to succeed, the applicant would need to show a real risk of suffering or ill-treatment in violation of constitutional rights, and the possibility of harm was insufficient. Ultimately, Phelan J. upheld the Tribunal’s decision, finding it was properly based on the applicants’ personal circumstances and the conditions in Greece. She ruled that the burden of proof was correctly applied and that the oral hearing requirements were satisfied through the interviews. The reliefs sought by the applicants were denied. The case reaffirmed the principle of mutual trust among EU Member States and clarified the requirements for proving a real risk of harm upon return.^[101]

Temporary protection

The information given hereafter constitute a short summary of the Annex on Temporary Protection for this report, for further information, see Annex on Temporary Protection.

Temporary protection procedure

• Key statistics: As of 2 February 2025, 112,189 individuals had registered for temporary protection in Ireland since 4 March 2022.^[102] Women and men aged 20 years and over made up 46% and 25% respectively of arrivals to date, while 29% were people aged under 20 years.[103]  As of 2 February 2025, 25,208 beneficiaries of temporary protection were residing in State-provided accommodation.[104] The number of beneficiaries staying in hosted or pledged accommodation arrangements was 36,532.[105] As of 2 February 2025, 23,803 individuals had accessed the labour market.^[106] Moreover, as of February 2025, a total of 17,420 Ukrainian students were enrolled in primary and secondary education in Ireland. Of these 10,483 students were enrolled in primary education and 6,937 were enrolled in secondary education.^[107] As of March 2025, 56,082 beneficiaries of temporary protection were in receipt of income support payments, while a further 14,774 were in receipt of child benefit payment.[108] As of March 2025, 87,639 medical cards have been issued to arrivals from Ukraine.[109]

Content of temporary protection

• Extension of Temporary Protection and renewal of permission to reside in the State: Following the Council’s extension of the Temporary Protection Directive until March 2026, in February 2025, the Department of Justice announced that holders of Temporary Protection would be permitted to extend their permission to the reside in the State for one year, until the 4^th of March 2026. In order to extend their permission, applicants are required to make a renewal application through the ISD’s online portal. Once a decision is made by the ISD to grant an extension of temporary protection, the applicant shall receive an Irish Residence Permit evidencing their permission to reside in the State. Applicants’ current permission remains valid while awaiting a decision on their renewal application.[110]
• Proposed extension and reduction in Accommodation Recognition Payment: In July 2022, the Government introduced an Accommodation Recognition Payment (ARP) for households hosting beneficiaries of Temporary Protection having fled the conflict in Ukraine. An initial payment of € 400.00 per month was paid to hosts and backdated as far as the 4 March 2022. The payment was subsequently increased €800.00 per month.^[111] In February 2025, Government Ministers signalled their intention to reduce the payment to €600.00 per month. These changes remained under review at the time of updating and had yet to take effect as of April 2025.^[112]
• Changes to Pledge Program Consortium: On 1 April 2025, it was announced that Helping Irish Hosts would step back from the Pledge Programme Consortium it previous ran in conjunction with the Irish Red Cross in order to managed pledged properties in which to accommodate Ukrainian beneficiaries of temporary protection. Additionally, Helping Irish Hosts will no longer be engaged in matching prospective hosts with individuals requiring pledged accommodation. Going forward, all duties have been taken over by the Irish Red Cross.^[113]

• Suspension of travel without biometric passport: As part of the emergency response to the invasion of Ukraine in 2022, Ireland temporarily suspended the requirement for Ukrainian nationals to provide a biometric passport in seeking to enter the State. While the suspension was activated, Ukrainian nationals could provide alternative documentation as proof of their nationality, including an expired biometric passport or internal passport. However, as of June 5^th 2024, all Ukrainian nationals seeking to enter the State were required to produce a valid biometric passport upon entry into the state. The rationale for the suspension in the first instance was a temporary response to the emerging crisis in order to ensure that individuals who could not access or renew their travel documents could still flee to safety. However, the situation has, according to the state, evolved since the outbreak of the war and it must now shift from an emergency response to a more sustainable response going forward.[114]

[1] International Protection Office, March 2025.

[2] ibid.             

[3] ibid.

[4] ibid

[5] ibid.

[6] Minister for Justice, Response to Parliamentary Question No 587, 12 December 2023, available here.

[7] Information provided by IPO, April 2024.

[8] Department of Justice, ‘Minister McEntee secures approval from Government to into measures of the EU Pact on Migration and Asylum, 27 March 2024, available: here.

[9] Irish Refugee Council, ‘Briefing paper to Oireachtas Justice Committee members on the EU Migration and

Asylum Pact’, 19 April 2024, available: here.

[10] RTÉ, ‘Dáil votes to opt into EU Asylum and Migration Pact’, 26 June 2024, available: here.

[11] Information provided for by Irish Refugee Council’s Policy and Advocacy Team, December 2024. 

[12] International Protection Office, March 2025.

[13] ibid.

[14] ibid. See also International Protection Office, April 2024.

[15] International Protection Office, March 2025.

[16] International Protection Office, March 2025.

[17] Advisory Group on Direct Provision, Report of the Advisory Group on the Provision of Support including Accommodation to Persons in the International Protection Process, 21 October 2020, available: here.

[18] International Protection Appeals Tribunal, February 2025.

[19] The Journal, ‘Taoiseach says Govt will be examining tougher border controls to prevent illegal immigration’, 11 January 2023, available: here.

[20] Information provided by Irish Refugee Council Information and Advocacy Service, December 2024.

[21] Minister for Justice, Response to Parliamentary Question No 759, 5 November 2024, available: here.  

[22] The Journal, ‘Taoiseach ‘encouraged’ after gardaí prevent 50 people entering Ireland from the UK with incorrect documents’, 26 May 2024, available: here.

[23] International Protection Appeals Tribunal, February 2025.

[24] ibid.

[25] ibid.

[26] ibid.

[27] ibid.

[28] International Protection Office, ‘Prioritisation and Acceleration of an Additional Category of Applicants’, available: here.

[29] ibid.

[30] ibid.

[31] Information provided by Irish Refugee Council Information and Advocacy Service, December 2024.

[32] Email response from International Protection Office, 23 April 2023.

[33] The Journal, ‘Irish officials to review ‘safe countries of origin’ designation on 8 nations within next year’, 3 June 2023, available: here.

[34] Section 72, IPA 2015.

[35] Department of Justice, ‘Minister McEntee announces new measures to expedite international protection application processing’, 30 January 2024, available: here.

[36] Department of Justice, ‘Minister McEntee announces new additions to Safe Countries of Origin list’, 2 July 2024, available: here.

[37] S.I. No. 725/2020 – International Protection Act 2015 (Safe Third Country) Order 2020, available: here.

[38] A v Minister for Justice, Ireland & Anor; B v International Protection Appeals Tribunal & Ors [2024] IEHC 183, available: here.

[39] Courts, Civil Law, Criminal Law and Superannuation (Miscellaneous Provisions) Act 2024, available: here.

[40] Department of Justice, ‘Minister McEntee publishes International Protection Modernisation Strategy’, 5 July 2023, available: here.

[41] International Protection Office, ‘What’s New’, 26th November 2024, available: here.

[42] ibid.

[43] ibid.

[44] Irish Times, ‘’Unprecedented’ increase in unaccompanied children seeking asylum in Ireland’, 15 January 2024, available: here.

[45] The Journal, ‘500% increase in migrant children arriving alone in Ireland to claim asylum’, 30 April 2024, available: here.

[46] RTE, ‘Gardaí probe claim Tusla care provider ‘fabricated’ files’, 29 February 2024, available: here.

[47] Irish Independent, ‘Nearly half of 39 children missing from state care were unaccompanied minors seeking asylum’, 2 July 2024, available: here. 

[48] Information provided by Irish Refugee Council Policy Officer, January 2024.

[49] Minister for Justice, Response to Parliamentary Question No 1084, 17^th January 2024, available: here.

[50] Information provided by Irish Refugee Council Information and Advocacy Service, January 2025.

[51] RTE, ‘Final decisions on Syrian asylum applications paused’, 10 December 2024, available: here.

[52] Irish Refugee Council, ‘Irish Refugee Council statement on pausing of Syrian protection applications’, 10 December 2024, available: here.

[53] ibid.

[54] Irish Human Rights and Equality Commisison, ‘Commission deeply concerned at State’s temporary pause on Syrian IPAS Applications’, 19 December 2024, available: here.

[55] Department of Children, Equality, Disability, Integration and Youth, ‘Statistics on International Protection Applicants not offered accommodation’, 12th December 2023, available: here.

[56] Information provided by Irish Refugee Council Information and Advocacy Service, January 2025.

[57] ibid.

[58] ibid.

[59] Department of Children, Equality, Disability, Integration and Youth, ‘Statistics on International Protection Applicants not offered accommodation’, 12^th December 2023, available: here.

[60] Information provided by Irish Refugee Council Information and Advocacy Service, January 2024.

[61] The Irish Human Rights and Equality Commission v. The Minister for Children, Equality, Disability, Integration and Youth of Ireland [2024] IEHC 493, available: here.

[62] Irish Human Rights and Equality Commission Act 2014, s.41.

^[63] Irish Human Rights and Equality Commission v. Minister for Children, Equality, Disability, Integration and Youth & Anor [2014] IEHC 493 [264], available: here.

[64] Irish Human Rights and Equality Commission, ‘State has appealed High Court judgment that it breached the right to dignity of unaccommodated International Protection Applicants’, 19 November 2024, available: here.

[65] Information provided by Iirsh Refugee Council Information and Advocacy Service, January 2025.

[66] Irish Examiner, ‘High Court hears of challenges against using tents to accommodate asylum seekers’, 26 July 2024, available: here.

[67] Information provided by Irish Refugee Council Information and Advocacy Service, January 2025.

[68] ibid.

[69] Dublin Inquirer,’ At Crooksling’s asylum shelter, harassment on the ground and drones in the sky’, 11 September 2024, available: here.

[70] International Protection Accommodation Service, ‘IPAS Weekly Accommodation and Arrival Statistics – 15th December 2024’, 15 December 2024, available: here.

[71] Irish Examiner, ‘Thornton Hall plan to house 1,000 asylum seekers thrown into doubt’, 5 November 2024, available: here.  

[72] Irish Times, ‘‘New Ministerial Order to be made in weeks’, says Dept’, 18 November 2024, available: here.

[73] Breakingnews.ie, ‘Thornton Hall protestor recorded making clear threat to security on site, court told’, 12 August 2024, available: here.

[74] Information provided by Irish Refugee Council Information and Advocacy Serivce, January 2025.

[75] International Protection Accommodation Service, ‘IPAS Weekly Accommodation and Arrival Statistics – 15th December 2024’, 15 December 2024, available: here.

[76] Minister for Children, Equality, Disability, Integration and Youth Roderic O’Gorman, Response to Parliamentary Question No 80, 31 July 2021, available: here.

[77] Information provided by IPAS, March 2024.

[78] International Protection Accommodation Service, Right to Reply, May 2025.

[79] Information provided by Irish Refugee Council Information and Advocacy Service, January 2025.

[80] Information provided by IPAS, November 2024.

[81] IPAS, Right to Reply, May 2025.

[82] HIQA, ‘International Protection Accommodation’, January 2024, available: here.

[83] ibid.

[84] Breakingnews.ie, ‘Non-compliance with food and protection found in some direct provision centres – HIQA, 27 November 2024, available: here.

[85] ibid.

[86] Department of Children, Equality, Disability, Integration and Youth, ‘Government agrees new comprehensive accommodation strategy for International Protection applicants’, 27 Marxh 2024, available: here.

[87] ibid.

[88] Department of Social Protection, ‘Daily Expense Allowance – Income Assessment’, 12 June 2024, available: here.  

[89] Information provided by Irish Refugee Council Information and Advocacy Service, January 2025.

[90] RTE, ‘Deportation orders up 140% on last year, cabinet to hear’, 28 October 2024, available: here.

[91] Damache v. Minister for Justice [2021] IESC 6. 

[92] Courts, Civil Law, Criminal Law and Superannuation (Miscellaneous Provisions) Act 2024, s.3, available: here.  

[93] Hussein v. Minister for Justice [2011] IEHC 171, available: here.

[94] M v. Minister for Justice [2024] IEHC 105, available: here.

^[95] J.R. (Algeria) v. International Protection Appeals Tribunal and the Minister for Justice [2024] IEHC 296, available: here.

[96] L.A. (a minor suing by his mother and next friend, A.A.) & Ors v International Protection Appeals Tribunal & Ors [2024] IECA 133, available: here.

^[97]  S.A. (Zimbabwe and South Africa) v the Chief International Protection Officer & Ors [2024] IEHC 477,  available: here.

^[98]  Irish Human Rights and Equality Commission v Minister for Children, Equality, Disability, Integration and Youth & Anor [2024] IEHC 493, available: here.

^[99] LK v. International Protection Appeals Tribunal & Ors [2024] IESC 42, available: here.

[100] C-297/17 Ibrahim & Ors v. Bundesrepublic Deutschland [2019] ECLI:EU:C:2019:219, available: here.

^[101] AAH & MAH v International Protection Appeals Tribunal & Ors [2024] IEHC 699, available: here.

[102] Central Statistics Office, ‘Arrivals from Ukraine in Ireland Series 12, 4 February 2024, available: here.

[103] Central Statistics Office, ‘Arrivals in Ireland Series 15’, 2 February 2025, available at: Central Statistics Office, ‘Arrivals from Ukraine in Ireland Series 15, 2 February 2025, available at: https://tinyurl.com/4ehcxu8y.

[104] ibid.

[105] ibid.

[106] ibid.

[107] ibid.

[108] Central Statistics Office, ‘Ukraine Statistics Hub – Beneficiaries of Social Welfare Payments among arrivals from Ukraine’, 21 March 2025, available at: https://tinyurl.com/3spmthfv.

[109] Central Statistics Office, ‘Ukraine Hub Statistics – Medical Cards issued to arrivals from Ukraine to date’, March 2025, available at: https://tinyurl.com/3spmthfv.

[110] Central Statistics Office, ‘Arrivals from Ukraine in Ireland Series 15, 2February 2025, available at: https://tinyurl.com/4ehcxu8y.

[111] Government of Ireland. Accommodation Recognition Payment, 5th January 2023, available at: https://bit.ly/3QlFnNw.

[112] RTE, ‘Possible cuts to payments to homeowners for hosting Ukrainians’, 25th February 2025, available at: https://tinyurl.com/2vpk8ack.

[113] Information provided by Helping Irish Hosts, April 1^st 2025.

[114] Department of Justice, ‘Important Information for Ukrainian Nationals’, 4^th June 2024, available at: https://tinyurl.com/yn7xyzts.