Good practices in terms of family reunification of unaccompanied asylum seekers children under article 8 of Dublin III Regulation, to be adopted during the emergency related to COVID-19 pandemic.


  1. The minor has expressed the will to reunite with a relative in another EU Member State but he/she didn’t apply for international protection yet:

according to the Circular of the Ministry of the Interior n. 0020359 adopted on the 9th of March 2020, Immigration Offices of the Police (Questura) are still receiving international protection applications, even though it’s not always possible to register the so called C3 form and Dublin Form. Therefore, unless the minor is about to turn 18, it could be considered to wait for the resumption of Police Offices’ regular activities, in order to lodge the application for international protection in its entirety, without gaps between identification and C3 registration. In the meantime, it is recommended to focus on the preparation of the documents that will be necessary in order to submit a family reunification request (family tree, minor’s consent, relative’s consent, interview on family bonds, reports on best interest evaluation, IDs).

  1. The minor was identified but couldn’t register C3 form because of the reduction of Police Offices’ regular activities:

A three-months term starts with identification as an asylum seeker, within which it is possible to lodge an official “family reunification” request under Dublin III Regulation: this term is not suspended. If, in the individual case, the term expires between April and mid-May, it is recommended to submit asap via email the documents related to FR request to the Italian Dublin Unit. At the resumption of Police Offices’ regular activities, registration of C3 and Dublin form will be necessary;

  1. Family reunification request was successful, but because of the reduction of Police Offices’ regular activities, it is impossible to notify the transfer decision to the applicant::

It is recommended to contact the competent Police Office in order to ask for the notification to be done by Certified Email or other alternative means as agreed with mentioned offices (for example via registered mail). Once the transfer decision has been notified, it will be possible to submit the request for transfer authorisation to the competent Judicial Authority.

  1. Family Reunification procedure was successful, but it’s impossible to transfer the minor to the other EU Member State because of the restrictions on movements imposed to deal with COVID-19 outbreak:

Transfers from Italy towards other EU Member States are currently suspended. According to article 29 of Dublin III Regulation, transfers must be carried out within 6 months from the acceptance of the other EU Member State in which family reunification must be realised therefore, if expiration of the term is approaching, contact asap the Italian Dublin Unit in order to ask for its support.

PLEASE NOTE: Turning 18 before the conclusion of family reunification procedure under Dublin III Regulation doesn’t affect its outcome: for the purposes of Dublin III Regulation, the applicant who is under 18 years old at the time he or she lodged the international protection application should be considered as a minor.

These are only suggestions, that do not exhaust possible scenarios: it is essential to proceed with a case by case evaluation when dealing with UASC family reunification procedure.

More in particular, if one of the situations described above at points 1 and 2 fits yours, it might be useful to report your case: EFRIS’s team will forward the information to the Italian Dublin Unit, so that its officials will monitor the C3 registration phase by Police Offices, and intervene when terms’ expiration approaches.

EFRIS’ team supports individual cases of UASC family reunification: contact us if you have any doubt or if you need clarifications.


Mobile +39 3404277780; +39 3428735259

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