20 • International Journal of Refugee Law, 2026, Vol. 00, Issue 00 5. Lessons learned 5.1. Outsourcing protection This article has argued that bilateral agreements in the context of statelessness and in the context of asylum seeking and irregular migration share a number of common features: they target populations deemed undesirable by the State, they exploit perceived ambiguity in legal obligations and a lack of accountability, and they are concluded between States with unequal economic power and at high cost. These similarities suggest that it is appropriate to understand the UAE’s agreement with Comoros as an externalization agreement; a further attempt to outsource protection. This article asserts that framing this agreement in this way offers a way to make sense of this development. The comparison of these two contexts also helps illustrate the circumstances in which bilateral agreements are likely to be adopted. Giuffré and Moreno-Lax (n 4) 84. See Orçun Ulusoy, ‘Financing Externalisation: The Role That EU Funds Play in Shaping the Turkish Asylum and Migration Policies’ (2025) 23 Journal of Immigrant & Refugee Studies 91. 155 See Tamara Tubakovic and Amy Nethery, ‘Attenuated Governance in Australia’s Offshore Immigration Detention Regime: How Financial Mismanagement Can Achieve Government Goals’ (2025) 23 Journal of Immigrant & Refugee Studies 121. 156 ‘UK Passes Law to Send Asylum Seekers to Rwanda After Months of Wrangling’ Al Jazeera (23 April 2024) https://www.aljazeera.com/news/2024/4/23/uk-law-to-send-asylum-seekers-to-rwanda-passed-aftermonths-of-wrangling accessed 12 June 2026. 153 154 Downloaded from academic.oup.com/ijrl/advance-article/doi/10.1093/ijrl/eeag028/8767365 by guest on 08 October 2026 Similarly, externalized migration arrangements are also often concluded between wealthy Global North countries and Global South countries. Bilateral agreements seek to interrupt the movement of asylum seekers and migrants from Global South to Global North countries by both preventing the arrival and, increasingly, preventing the departure of these groups from their countries or region of origin. For this reason, these agreements are often initiated by wealthy Global North countries with Global South partners which are geographically positioned to intercept migration flows (such as the movement of Syrian refugees through Turkey to the EU). Alternatively, partner States (such as Nauru and Papua New Guinea in their respective agreements with Australia) are incentivized by the financial and other benefits discussed above, and often a lack of other sources of revenue, to take on the task of detaining asylum seekers and processing asylum claims. Under these arrangements, Global South countries act in the ‘stead and/or for [the] benefit’ of wealthy Global North countries.153 Payments may take the form of financial aid (for example, the Facility for Refugees in Turkey, established under the EU-Turkey Statement of 2016 in exchange for Turkey’s cooperating in ending irregular migration into the EU),154 investment in the country for the purpose of establishing and operating asylum processing facilities and systems (as under Australia’s agreements with Nauru and Papua New Guinea),155 or investment for broadly defined ‘capacity building’ purposes. While outsourcing in the business context usually promises lower costs, attempting to outsource state obligations in the contexts of statelessness and irregular migration and asylum seeking comes with a high price tag. The UAE paid US$200 million to the Comoros for the supply of–at the higher end of the estimate—120,000 passports, coming in at a not insignificant cost of $1666 each. The costs of establishing transfer and offshore processing arrangements in third states are even more exorbitant. Under the proposed agreement between the UK and Rwanda, it was estimated that the deportation of 300 asylum seekers to Rwanda would cost £540 million: nearly £2 million per person.156

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