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By Agnese Pacciardi (School of Global Studies, University of Sussex)

In June 2026, the European Union’s Pact on Migration and Asylum will enter into force. The Pact explicitly recognises the role of civil society organisations and NGOs in EU migration management, acknowledging their practical expertise, especially in working in contexts that are outside the EU. In recent years, EU migration governance has increasingly relied on partnerships with third countries, where border control, development cooperation, and humanitarian assistance overlap. Instruments such as the European Trust Fund for Africa (EUTF) and the Neighbourhood, Development and International Cooperation Instrument (NDICI) show how development funding is increasingly used to support migration management beyond EU borders. In this context, NGOs operating in countries of origin and transit have become central actors in how these policies are carried out on the ground. Much has been written about NGO criticism of EU migration policy over the past decade. Far less attention has been paid to how NGOs actually engage with these policies in practice. What does it actually mean for an organization committed to humanitarian principles to deliver EU-funded programmes inside the EU’s migration machine? My research answers this question by looking at how NGOs in Libya navigate funding pressures, ethical dilemmas, and complex local realities while delivering humanitarian and development assistance in a context heavily shaped by migration control objectives.

Libya and EU Externalisation Strategy

Libya sits at the centre of EU externalisation efforts. Since 2017, the Italy-Libya Memorandum of Understanding (MoU) has funded Libya’s Coast Guard to intercept migrants at sea and return them to detention centres where abuse, forced labour, and torture are widely documented. Research and reports have also documented NGO involvement in alleviating the suffering of migrants in some detention centres, raising questions about whether such engagement is compatible with their humanitarian mandate. This coupling of migration control with development and humanitarian aid is not incidental but is structural, as it is openly acknowledged in Article 2 of the MoU itself.

In this context, NGOs in Libya work in an environment shaped by both urgent humanitarian needs and migration control policies. In my research I show how they navigate this terrain through two seemingly distinct but actually overlapping approaches. The first is what I call “pragmatic developmentalism”: accepting EU funding despite reservations about its political objectives, and focusing on delivering essential services and addressing urgent needs. This approach may involve engaging with local authorities and navigating informal power structures, but it remains oriented towards concrete outcomes for communities. The second is “principled humanitarianism”: an ethics-driven approach in which humanitarian imperatives take precedence over other objectives. This emphasises neutrality, impartiality, and the obligation to provide assistance based on need. In practice, it is based on the belief that NGOs can preserve spaces in which humanitarian action can operate independently of the political agendas that shape its funding context.

The RSSD Project: Where Development Meets Migration Management

The EU-funded Recovery, Stability and Socio-Economic Development (RSSD) project offers a concrete illustration of these dynamics. Targeting municipalities along migration routes in Libya, the project stabilises communities and supports local health systems, such as restoring health centres, delivering medical supplies, and training local staff. While these are developmental outcomes, practitioners themselves recognise that the project operates within a wider strategy aimed at discouraging onward movement towards Europe.

Interviews with NGO workers reveal the two overlapping logics at work. On one hand, they  accept EU funding to deliver essential services, despite some political reservations about the EU migration agenda. On the other they seem preoccupied with maintaining what they describe as ethical “red lines.” What emerges from their accounts is that the tension between pragmatism and principle is not simply an individual ethical dilemma. It may reflect a structural feature of contemporary migration governance itself. NGOs are not only making difficult choices, they are part of the mechanism through which migration policies are implemented on the ground. By delivering services within containment-oriented strategies, NGOs can simultaneously alleviate immediate harm and contribute to stabilising those same strategies. Many practitioners openly acknowledge this ambivalence. One NGO worker describes the tension in stark terms as “whitewashing”, suggesting that the humanitarian framing of their projects can serve to mask a much less humanitarian political agenda. As such NGOs operating within these frameworks are key actors through which migration policies take shape in practice.

Looking Ahead: NGOs and the Future of EU Migration Governance

While the extent to which NGOs manage to maintain independence and stay neutral remains up to debate, the interaction between pragmatic developmentalism and principled humanitarianism shows that NGOs are not simply passive implementers of EU policy. They interpret, adapt, and sometimes push back against EU objectives while continuing to deliver essential services on the ground. At the same time, their work can also indirectly support EU agendas. By framing migration through development and humanitarian action, EU external migration policies can appear more technical and less political, while part of the responsibility for their implementation is carried out by NGOs.

As the EU continues to expand its externalisation strategy, including discussions around “safe third country” arrangements and the delegation of asylum processing, the role of NGOs in transit countries is likely to grow. Understanding their work beyond the simple view of NGOs as either critics of EU policies or their enforcers is crucial for policymakers and civil society actors. It highlights the tensions that arise when migration governance is outsourced, and shows that migration policy is shaped not only by states and institutions, but also by the everyday decisions and principles of the organisations working on the ground.

Agnese Pacciardi is Research Fellow at the School of Global Studies, University of Sussex. Her work focuses on borders, mobility, and security through critical lenses. In her research, she primarily delves into European border security, humanitarianism and development cooperation in North and West Africa, exploring the impacts and implications of these policies on the communities they affect from feminist and decolonial perspectives.

The post When Development Policy Becomes Migration Policy: Side Effect or by Design? appeared first on Ideas on Europe.

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