Introduction

In July eight EU countries – Italy, Austria, Croatia, Slovenia, Slovakia, Czechia, Cyprus and Greece – launched an initiative to change the EU Strategy on Syria, calling in their “non-paper” for the normalisation of the Syrian regime. As the foreign ministers of Italy and Austria termed it in a joint op-ed: “We believe it is time to rethink our approach to Syria. This involves asking uncomfortable questions: how can we ensure that Syrian citizens have economic prospects and are not forced to embark on a dangerous journey to Europe? How can we help create the conditions for people to return to Syria?“ The eight countries called for a meeting of EU states, which is happening today, 13th of September, and will focus on these and some additional questions, including discussion on appointment of an EU envoy for Syria, a “better balanced approach to the parties in Syria”, how can EU contribute to creating conditions for the safe, voluntary, and dignified return of Syrian refugees, and how can EU’s early recovery approach be developed to address long-term needs in Syria, among others.

SACD has prepared a note responding to the key issues raised in this initiative and distributed it to all the EU members states which will be attending today’s meeting.

The key point which formed the basis of our intervention emphasizes that the notion that the European Union should normalize relations with the Assad regime is deeply flawed and presents catastrophic implications for the safe and dignified return of displaced Syrians and the future of the political process. The Syrian Association for Citizens Dignity has consistently, over the past six years, consulted and surveyed displaced Syrians to collect reliable data on their attitudes and intentions, which systematically debunks the idea of normalization and demonstrates how such a policy would entrench the regime’s power, exacerbate existing humanitarian crises, and delay or entirely prevent the return of Syrian refugees.

The Fallacy of Assad’s Control

One of the key arguments made in favour of normalization is the belief that Assad controls over 70% of Syria and thus must be engaged. However, this narrative is based on a profound misunderstanding of the realities on the ground. While the regime nominally controls some areas of the country, key areas are under the influence or complete control of Iran-affiliated militias, such as the IRCG, or Hezbollah, rather than the Assad regime itself​. This is especially so in border areas, which the regime does not effectively control (not the border with Jordan nor Iraq nor Israel and definitely not with Turkey). These areas are strategic in nature expanding from: Al-Boukamal, to Deir Ezzor, to Palmyra, to Homs, to Damascus and reaching Daraa and the Lebanese, Jordanian and Israeli borders, which makes the creation of “safe zones” or “safe areas” within the territories tagged as “regime-controlled” a very hard to attain proposition. Assad has focused primarily on centralizing security forces to better enforce draconian policies against civilians rather than ensuring any meaningful political or security reforms, rebuilding the economy, stabilizing government institutions, improving human rights, or addressing critical humanitarian issues like detainees​, whose release remains the ultimate priority issue for the vast majority of displaced Syrians before they would even contemplate return. In addition, the ongoing violence in areas like Daraa, continuing repression, arbitrary arrests, enforced disappearances in Damascus, Homs, and other areas, as documented by credible organisations such as SNHR, are causing increased displacement and the rise in violence, demonstrating an absence of regime’s control. This lack of genuine and meaningful control of the country, and even a semblance of commitment to reform, undermines the argument for normalization as a path to making the safe and dignified return of refugees possible.

Arab Normalization: A Failed Experiment

The Arab normalization process offers a cautionary tale for the EU. Despite efforts by Arab states to reintegrate Syria diplomatically, the regime has failed to meet any of the key demands laid out by the Arab Liaison Committee (ALC), including the cessation of drug trafficking, the establishment of conditions for refugee returns, and the resumption of the Constitutional Committee process. Instead, drug smuggling has tripled, and none of the humanitarian or political goals have been achieved. In fact, diplomats from the main Arab countries now express regret for initiating normalization as it backfired on all fronts. This experiment should serve as a stark warning to the EU that normalization without accountability and evidence of tangible progress would only embolden Assad to continue his oppressive policies.

The Regime’s Weaponization of Humanitarian Aid

Normalization would enable Assad to continue weaponizing humanitarian aid, a practice thoroughly documented over the past decade. The regime has systematically manipulated aid delivery to force opposition-held areas into submission, starved civilian populations, and used aid to fund its military campaigns. Any normalization effort would likely reinforce these tactics, making it harder for international organizations to deliver aid to those in need without regime interference. This manipulation not only exacerbates suffering within Syria but also further destabilizes the region, making it nearly impossible for refugees to return to safe conditions​.

Refugee Return: An Unrealistic Promise under Assad

The conditions for a safe, voluntary, and dignified return of Syrian refugees are far from being met, and normalization would only prolong their displacement. According to the UNHCR, less than 1.1% of Syrian refugees expressed a willingness to return under current conditions​. Refugees demand improved security, access to livelihoods, and the resolution of issues surrounding detainees—conditions that the Assad regime shows no interest in fulfilling. In fact, the most recent decrees have further empowered the regime to seize and appropriate the properties of opposition-affiliated individuals, deterring any possibility of return​.

The regime’s refusal to address these fundamental issues, combined with its policies of “political cleansing” and labelling refugees as “traitors,” ensures that refugees will not return as long as Assad remains in power​. Daraa is a very bleak example of what a normalization would bring to the rest of Syria: Daraa is an area that “reconciled” with the regime in 2018 and after five years of nominal control (Iran and Russia still have a huge influence there) and “reconciliation”, there are only new waves of displacement towards Europe and internally. Precarious security conditions, assassinations, military conflagrations, forced recruitment, soaring drug trafficking, and public unrest and anti-regime demonstrations in neighboring As-Suwayda similar to the uprising in 2011, are now a daily reality for the remaining people in Daraa. Just last month (August), the head of the Military Security Branch in Daraa threatened the residents of the town of Mahaja in the governorate of Daraa with “turning their town into a Gaza-like area” if they do not submit to the regime rule and conditions. This type of environment and policies will not only never allow the return of refugees, but is and will continue to drive new waves of displacement.

Corruption and Economic Recovery: A Non-Starter

Another argument for normalization is that it could lead to economic recovery in Syria. Yet, the Assad regime’s deep-seated corruption makes this prospect highly unlikely. Despite years of international efforts, the regime has shown no capacity or interest in using funds transparently or equitably. Arab normalization failed to improve the Syrian economy, with the Syrian pound plummeting and drug trafficking becoming a mainstay of the regime’s revenue​. Expecting Assad to fairly administer any recovery funds is not only naive but also reckless. It would be a misuse of European taxpayers’ money and would further entrench the regime’s corrupt practices, with no benefit to ordinary Syrians.

It is also important to remember, that while improvement in the overall economic situation of the country and the living conditions of ordinary Syrians is one of the top pre-requisites for Syrians to remain in Syria and stop thinking about finding a new destination, nevertheless, improving the security situation along with addressing the detainees dossier remains the top requirement for refugees and IDPs to return to regime-controlled areas.

Revitalising the Political Process through Normalization: A Utopia

Concessions-based policies with the Syrian regime have proved to be a long and painful experience, doomed to failure and, ultimately, a frivolous approach. The “Four Baskets”, “Constitutional Committee”, “Step for Step” and finally the Arab normalization have all proved that the regime is not willing and in some cases incapable of making any concessions or showing any flexibility in order to kick-start the political process or make any improvement in the security and living conditions of ordinary Syrians.

In fact, all these approaches further emboldened the regime and encouraged its obstructive role in the political process, further weakening the position of some regional and international backers of the political process, making them lose most of their political and economic leverage.

The only measures in the last few years, since the end of the main military operations, that showed impact on the regime and constituted genuine leverage and pressure are the targeted sanctions, such as the EU sanctions and the “Caesar Civilian Syrians Act”.

Flawed Premise for Discussion on Change in EU Strategy on Syria

 Normalizing relations with the Assad regime would not bring stability, peace, or a resolution to the refugee crisis. Instead, it would solidify Assad’s authoritarian rule even though a hallow one, worsen humanitarian conditions, and delay the safe and dignified return of millions of displaced Syrians. The lessons of the Arab normalization process make it clear that engaging with Assad without significant concessions on human rights, governance, and security would backfire, prolonging the suffering of the Syrian people and position the EU as a partner or accomplice in the eyes of Syrians and the international community having made equally incomprehensible and fatal U-turn on their policies in Syria.

The EU must reject the false promise of normalization and focus instead on creating viable alternatives that prioritize gaining or at least conserving whatever political and economic leverage it has in order to pursue it main agendas in Syria such as human rights, refugee safety, and long-term stability in Syria. This is evident from factual answers to questions which are supposed to drive the discussion on new EU strategy:

  • Should the EU appoint a Syria Envoy to engage with all Syrian parties and support the UN-led political process?

The harsh reality that the EU has to face is that the Syrian regime is happy to continue operating as a rogue state as long as it remains in power while managing the political process to make gains, mainly: normalization and economic recovery (for the regime, not the country). Thirteen years of “political process” and various ad hoc initiatives proved beyond any doubt that the regime is not interested in any political transition or reforms.

Before considering any policy change, it is imperative to make a thorough review of the results of concession-based initiative towards the Assad regime as previously mentioned.

The objective of departing from a status-quo is to go in the right direction and not just to move in any direction (possibly backwards). The goal should be to make progress not random motion that might benefit the regime and hurt the Syrian people. A political misstep by the EU and the international community might translate into an irreversible damage to the future of Syria and its people.

Balancing the short and long-term effects of any Syria policy should be an integral part of the policy analysis, even the solutions that could seem as an immediate relief for the Syrian people might hide a very hefty price for them in the long term and some irreversible damage to their future especially if such concessions or ill-devised policies lead to strengthening the Assad regime, which remains the biggest obstacle stopping refugees from coming back.

The Syrian regime is organically attached to the Iranian presence in Syria, detaching them and hoping the regime to pursue independent polices is impossible. The Iranian model for Syria is a fragmented and weak government that will allow the establishment of influence and control areas fully administrated by Iranian proxies, this approach clashes diametrically with the notion of a centralized strong government with good governance capable of providing a safe environment for the return of refugees and an economic recovery.

The regime inner circle is fully reliant on drugs trafficking, in partnership with pro-Iranian forces, there is no way that this partnership can be broken nor for the regime to give up that source of funding.

All the aforementioned arguments raise an existential question about the value and benefits of engaging diplomatically with the regime beyond what the Office of the Special Envoy (OSE) and the ALC are doing. Such engagement will only provide the Syrian regime with gratuitous political leverage and will send very warrying signals to the Syrian people, and one damming message to refugees and IDPs: situation in the country will only get worse, stay where you are.

  • Should the EU better balance its approach to the parties?

The Assad regime are not the actual rulers, and any further “legitimization” or the regime will just give it more power to further oppress the Syrian people under its control. But the dangerous concept here is to talk about “reconciliation” instead of “transition”, which is what UNSC 2254 dictates. It is a very flawed logic to think that a regime that never engaged in good faith in the political process so far will do so by giving it concessions and political and economic perks instead of gaining more political leverage of it and find the right mechanisms to pressure it.

There has been many political initiatives throughout the last few years: The Four Baskets, The Constitutional Committee, and now Step for Step, that they were all detours from the true essence of 2254 and were all designed to please the Assad regime rather than the opposition (which was always cooperative despite its shortcomings and self-inflected problems), and still the regime did not truly engage in the political process and was an obstructing force.

The latest initiative (Step for Step) which in theory is based on reciprocal concessions between the regime and the opposition was reduced to some high-profile diplomatic visits to Damascus and the Arab normalisation itself, but the regime offered nothing in return, and it seems that the regime was asked for none (we say “seems” since this initiative has been conceived and executed in a complete absence of transparency). This trend of giving concessions to the regime has proven to be totally ineffective and counterproductive, and it only emboldened the regime to be more obstructive in the political process, but most importantly it is a “carte blanche” to pursue its oppressive and corrupt policies against Syrian people.

Again, the OSE is the appropriate interlocutor to spearhead the political effort with both sides (the regime and the opposition), while the EU should not pretend to play the neutrality card because the EU is expected to stand for certain interests and values, and cannot be on the wrong side of history regarding the conflict in Syria and the future of its people.

  • How can the EU enhance cooperation with the UN Syria Envoy and support the resumption of the Constitutional Committee (CC) as outlined in UNSC Resolution 2254?

The EU has an existential interest in driving the reform of the political process under the Resolution 2254 to elevate the creation of a safe environment to the top of the political agenda. The Office of the Special Envoy must work to focus the process on securing the rights and minimum conditions for return expressed by refugees and IDPs as a fundamental part of any political solution and its individual elements, such as a new and credible constitution or elections. Adventurism and dubious “pilot projects” on return must be rejected and abandoned as they would inevitably lead to new waves of displacement towards Europe rather than any sustainable, safe and dignified return. Working towards creating a sustainable safe environment in Syria is the only practical and logical path to a comprehensive and legitimate political solution that would lead to the return of the displaced people.

Donor countries and the main backers of the political process must be made aware of the fact that some ad hoc solutions and “pilot projects” are inadvertently helping the Syrian regime gain legitimacy and normalisation, which would seriously decrease the leverage available to the international community in any effective future negotiations with the regime to reach a political settlement.

The OSE needs political leverage and pressure tools to strengthen its position mainly in front of the Syrian regime and its backers. The OSE also needs alternatives to the current ad-hoc approaches.

  • How can the EU contribute to creating conditions for the safe, voluntary, and dignified return of Syrian refugees?

According to UNHCR, the key improvement that refugees asked for in order to reconsider their decision about not returning was ‘improved safety and security’ followed by ‘access to livelihood/work opportunities’. Since the Arab normalization the regime took further steps to prevent the return of refugees such as a new decree back in November 2023 that would allow the regime to seize and administrate properties belonging to citizens deemed as ‘traitors’ which is the usual accusation used against opposition affiliated Syrians. The Syrian regime also took steps and measures (mainly security in the shape of detentions) to further prevent the return of refugees and persisted in making Syria not a safe place according to HRW report in September 2023. The regime cannot lead the change needed to make Syria safe and to welcome refugees back for the following reasons: The regime has carried out a ‘political cleansing’ in society and considers the vast majority of refugees as political enemies and a huge security risk if they return to Syria.

UNHCR must take into account the minimum conditions for return defined by the displaced Syrians when determining when it is safe to return. It must meaningfully engage with Syria’s displaced in conversations on the reform of the Regional Operational Framework and assess the current thresholds and adjust them in line with their views. UNHCR must also provide clear and timely information about the current conditions, its ability to provide access to and protection of returnees in Syria and refugees in host countries who may be in danger of forced or premature return, as well as the work that needs to be undertaken to meet the minimum conditions for return.

The European Union has a vested interest in maintaining stability in its immediate neighbourhood and preventing a renewed refugee crisis. As Türkiye plays a critical role in containing refugee flows into Europe, the EU’s approach should prioritize diplomatic engagement, preparedness, and adherence to human rights standards. In addition, the European Union has a crucial role in ensuring that the rights and safety of Syrian refugees are upheld amidst Türkiye’s evolving policies and potential normalization with the Assad regime. The EU’s actions should focus on preventing forced returns, advocating for a safe environment in Syria before any repatriation, and opposing the normalization of relations with Assad without significant human rights reforms.

  • How can the EU’s early recovery approach be developed to address long-term needs in Syria? Can the EU compromise to support the Early Recovery Strategy promoted by the UN Coordinator?

The main obstacle facing an economic recovery (if incentives and programs and funds are given) or even the delivery of aid is the systematic corruption of the regime which goes back to decades before 2011. Expecting the regime to fairly and transparently administrate any early recovery or reconstruction funds is a reckless use of the European taxpayers’ money.

Assad’s current economic model is entirely dependent on manufacturing of Captagon and its regional distribution, which is under the direct supervision of the regime and pro-Iranian forces, and it is considered to be the main source of illicit funding for the regime and the Iranian-affiliated militias. The decision of stopping such activity is not up to the regime.

The council of the European Union stated that the Captagon manufacturing and trading has become a “regime-led business model, enriching the inner circle of the regime and providing it with revenue that contributes to its ability to maintain its policies of repression against the civilian population”. The US estimated in March 2023 that trade in captagon by the regime has “become a billion-dollar illicit enterprise”, which means that even thinking about providing the regime and its allies in Syria with alternatives is extremely difficult.

The exchange rate of the Syrian pond against the US Dollar at the beginning of the Arab normalization period was 7500 Syrian pounds per Dollar, now it’s 15000 despite attempts to open commercial routes between regime-controlled areas and neighbouring countries that were also heavily disrupted and used for smuggling too. All previous data indicates that the regime in one year of normalization with Arab countries coupled with ongoing drug trafficking did not reflect on the Syrian economy. The main challenge facing the economic recovery in Syria is the corruption of the regime, same applies to aid.

Before anything else, there must be an independent, objective audit of how the EU funds are being used by the UN agencies and international and Syrian organisations working on the ground to prevent aid manipulation and interference by the Syrian regime in furtherance of its repressive, criminal agenda, before any early recovery approaches are even considered, if the EU taxpayers are to be protected and for the aid to have any meaningful impact on Syria. A comprehensive review of the policies and practises of UN agencies involved in humanitarian aid distribution in Syria is needed before any plans are developed for the organised, safe, voluntary and dignified return of displaced Syrians following a comprehensive political solution with robust international guarantees. It is necessary to ensure humanitarian operations are conducted in line with the humanitarian principles and work that goes beyond life-saving aid is in line with the 2018 UN Principles and Parameters for UN assistance across Syria.

  • How can the EU address unintended negative effects of sanctions on the population and over-compliance in the banking system?

Imposing sanctions proved to be the only way to build political leverage since they impactfully affected the regime. Investing effort into designing smarter and further-reaching ones could be very effective in getting limited yet useful concessions from the regime.

It is clear that the international sanctions imposed on the regime for its brutality and repression of the Syrian people are not designed to target the general population. On the contrary, the countries which have imposed the sanctions remain the largest donors of humanitarian and medical aid to the Syrian people.

Sanctions cannot be lifted as long as the rights of the displaced are denied, as long as there are not minimum conditions for their safe, voluntary and dignified return. Any other scenario would acknowledge Bashar Al-Assad’s impunity for horrendous crimes of its regime and its allies, with lasting and irreversible destructive consequences for Syria and the region.

The only real mechanism to alleviate any unintended effects of the sanctions is through the continuous auditing and scrutinizing of the aid delivery mechanisms to ensure that they reach the intended segments of the Syrians society, since lifting the sanctions will only benefit the inner circles of the regime and their financial proxies.

  • Could the EU explore and develop soft power tools, such as cultural diplomacy? Why is cultural heritage protection considered beyond the red lines?

These issues are of minimal concern to displaced Syrians and extremely marginal for civilians in regime-controlled areas where they would be more interested in recovering their properties for their immediate livelihood, as opposed to the rumoured approach of setting up “safe zones” for return in Assad-held areas, which we would rather have transparently addressed by the EU. It is also difficult to imagine a genuine interest on the regime’s side in such approach since the regime has actively targeted emblematic buildings and structures considered as part of the cultural and historic heritage of Syria and humanity, unless such approach could be used by the regime to funnel some extra funds for its inner circle.

The planning on return, which is allegedly being undertaken, based on the Area Based Returns Support (ABRS) Roadmap and various ideas on pilot projects that would compartmentalise the return process – is highly problematic as it proceeds with the current reality described in the previous sections of this document. The baseline for return, as per the UNHCR strategy documents, is impossible without a political agreement which would provide for international guarantees for establishment of a clearly defined safe, clam and neutral environment and minimum conditions that must be implemented before any safe, dignified and voluntary return is possible. Such “safe zone” planning threatens to render the any future political solution – whose backbone is in the safe and dignified return of over 13 million displaced Syrians, more than half of the country’s population – meaningless. We call all involved in this process to revert to the existing framework provided by UNHCR’s CPSS and ensure full transparency and meaningful consultation with displaced Syrians in any planning activities concerning return.

In its strategic and operational documents, UNHCR outlined three criteria that need to be met inside Syria before UNHCR could move from “phase 1” (the current phase according to UNHCR as of June 2022) to “phase 2”, the phase in which UNHCR could start “facilitating” large- scale voluntary return:

    • Legal frameworks, guaranteeing rights of returnees and unhindered access to them as well as return areas, must be in place.
    • There is clear evidence that a list of 22 protection thresholds are being met in the place of return.
    • Refugees actively request support from UNHCR to return, “in large numbers”.

We have to highlight the point number 2 as a one of the root-cause errors in understanding the current reality: Protection thresholds cannot be met or implemented at local levels, the fact that there are various de-facto authorities across three main areas in Syria makes it really difficult to imagine how a small part of each of these areas might have better security and legal and living conditions than its surroundings.

“Safe zones” in Assad-held areas approach will lead to more pressure on refugees in hosting countries, including the increase in hate speech and dehumanisation targeting refugees, as this has been employed by political parties in countries like Lebanon and Turkey for political gains, while in reality refugees will not be able to return.

The current planning on ABRS seems to be giving the Syrian regime (the same regime that is responsible for the displacement of millions of Syrians) a central role to dictate how return assistance should be implemented. This is simply staggering.

The latest surveys of Syrian refugees conducted by SACD suggest that more than 70 percent would rather risk their lives in trying to reach Europe than accept forced return to Assad-held areas, including in so called “safe zones”.

If such plan was to be adopted, the EU must prepare for the possibility of increased refugee flows resulting from such policy shifts. This involves enhancing the capacity of asylum systems and ensuring that frontline member states are adequately supported, expanding the EU’s asylum capacities, ensuring that all member states share the responsibility for processing and resettling refugees and provide additional resources and support to border states, such as Greece and Bulgaria.

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