Using AI tools to predict migration flows will lead to human rights abuses and must cease


Along with a group of human rights organisations and academic experts, we have signed an open letter to an EU-funded research project, ITFlows, which is developing a tool to "predict migration flows" and "detect risks of tension related to migration". The letter calls on the consortium to "immediately halt the use of the EUMigraTool and stop pursuing the use of any and all technologies that can be used in securitisating migration, and criminalising movement and solidarity with people on the move."

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The letter was drafted and coordinated by Access Now.

Text of the open letter

Dear members of the ITFlows Consortium,

We, the undersigned civil society organisations and individuals, call on the Consortium to immediately halt the use of EUMigraTool and stop pursuing the use of any and all technologies that can be used in securitisating migration, and criminalising movement and solidarity with people on the move. 

We are alarmed by the potential, and probable, misuse of the forecasting tool — designed to ‘predict migration flows’ and ‘detect risks of tensions related to migration’ — by authorities to interdict border crossings. Furthermore, the project itself has the power to legitimise the notion that it is possible to predict migration without risking fundamental rights — it is not. In particular, we are concerned that: 

  1. Predictive technologies risk being re-purposed for the securitisation and criminalisation of migration. We acknowledge that the predictive tool is designed to be used for humanitarian purposes only, and solely by NGOs and municipalities involved in the reception of asylum seekers and third country nationals in need. Despite this, the project concurs building the infrastructure for predictive migration technologies more broadly, and does not offer sufficient safeguards to prevent state authorities and EU agencies from exploiting the forecasting tool for border management and security purposes. We have deep concerns that the predictions could easily be used for the purpose of preventing migration, generating and exacerbating assumptions that particular groups present a ‘security risk’ or a threat of  ‘irregular migration’, and encouraging punitive responses geared toward the interdiction of movement.
  2. The societal risks posed by the EUMigraTool cannot be mitigated. As indicated by the ITFlows Consortium itself, the project has the potential to seriously jeopardise a range of fundamental rights, such as the right to asylum and non-discrimination. While we welcome the Consortium’s efforts to propose mitigation measures to minimise negative societal impacts, such as monitoring and compliance activities, these will simply not be enough to prevent the infringement of the fundamental rights of the people that the project seeks to assist —  the ITFlows research would become an enabler of fundamental rights violations.  
  3. The project offers a techno-solutionist answer to migration responses without addressing the structurally oppressive dimension of EU migration policies. The EUMigraTool is at odds with the stated objective of the ITFlows project, i.e. to seek improved migration responses and ensure migrating people’s better enjoyment of fundamental rights. The lack of humane, needs-based responses to migration in the EU does not derive from a shortage of information on migration flows, but rather from the constant criminalisation of solidarity with people migrating, and of migration itself. By engaging in this project, the Consortium will legitimise the idea that migration is a problem and that it can be fixed via technical solutions, discharging institutions of their responsibilities regarding the deterioration of fundamental rights at the EU borders and within EU member states.  
  4. Predictive analytics tools are under interinstitutional negotiations in the framework of the EU AI Act. Civil society has been calling on the EU to put fundamental rights first in the proposed Regulation on Artificial Intelligence, including in the migration context. As part of the ongoing interinstitutional negotiation on the proposed text of the Regulation, several Members of the European Parliament are calling for a ban on predictive analytics systems that can lead to the interdiction of border crossings and that will irreversibly undermine fundamental rights. We urge the ITFlows project to refrain from developing a system that should be prohibited under the upcoming Regulation.

Despite the Consortium’s good intentions, we are deeply concerned that the EUMigraTool will be used not as an instrument of protection, but rather of coercion. We call on the ITFlows Consortium to:

  • Withdraw the EUMigraTool and refrain from developing any systems that are being considered for strict regulation under the Artificial Intelligence Act;
  • Reflect on the extent to which this project legitimates the use of technological tools in the securitisation of migration and the criminalisation of movement; and
  • Oppose the deployment of tools to predict migration patterns insofar they can be used to violate fundamental rights and international human rights law.


Access Now 

Bits of Freedom 

Border Violence Monitoring Network

Dr Cory Rodgers, Senior Research Fellow, Refugee Studies Centre, University of Oxford

Dr Derya Ozkul, Senior Research Fellow, Refugee Studies Centre, University of Oxford

Dr Hanno Brankamp, Departmental Lecturer in Forced Migration​at at the Refugee Studies Centre, University of Oxford

“Dr Niovi Vavoula, Lecturer (Assistant Professor) in Migration and Security at Queen Mary

University of London”

“Dr. Jan Tobias Muehlberg

imec-DistriNet, KU Leuven, Belgium”

Državljan D / Citizen D

European Center for Not-for-Profit Law (ECNL)

European Digital Rights (EDRi)

European Network Against Racism (ENAR)

Fair Trials

Homo Digitalis 

IT-Political Association of Denmark (IT-Pol)

Petra Molnar, Associate Director, Refugee Law Lab, York University

Platform for International Cooperation on Undocumented Migrants (PICUM)


Image: ITFlows

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