As is known, shortly before the 15th Saeima elections, Interior Minister J. Dombrava has announced the so-called 'immigration restriction plan.' From public statements on social networks, it may appear that the plan aims to significantly reduce immigration and provide strict legal consequences when set requirements are not met. However, upon examining the plan's content and its measures, it is clearly evident that its actual impact on immigration is considerably smaller (if not 'none'), than one might infer from public communication. Therefore, the question arises whether the said plan is essentially aimed at practically implementable and long-term effective halting of immigration, as most Latvian residents wish, or whether its main goal is to demonstrate political action before the upcoming Saeima elections. The plan is based on the report of the Saeima Parliamentary Investigation Commission 'On problems in national and European Union level immigration regulation and executive institutions' work causing mass entry and stay of third-country citizens in the Republic of Latvia.' The commission's work also involved deputies from various anti-state political forces represented in the Saeima, including Svetlana Čulkova from 'Stabilitātei!', Selma Levrence from 'Progresīvie', and Edmunds Zivtiņš from LPV. Then, in order: 1. The report does not provide specific measures aimed at promoting the departure of immigrants already arrived in the Republic of Latvia. Likewise, the report does not contain proposals aimed at reducing immigration for work purposes, making entry conditions stricter, or making the process less attractive. Thus, using the term 'reduction' refers to reducing the immigration flow, not reducing the total number of immigrants in the country. With such a basic premise, the total number of immigrants in Latvia will continue to increase (slower, but increase). The report examines various solutions and mechanisms intended for accounting, control, and possible reduction of future immigrant flows, but does not provide specific measures aimed at completely halting this immigration flow and achieving the departure of already arrived immigrants. 2. The report acknowledges that competent state institutions – the State Border Guard (VRS), State Police (VP), Office of Citizenship and Migration Affairs (PMLP), Ministry of Interior (IEM), and other institutions – currently lack sufficient resources to fully control immigration processes, verify the authenticity of documents submitted by legal entrants and the truthfulness of declared entry purposes, and properly monitor immigrants' behavior after arrival in Latvia. To reduce the workload of these institutions, it is planned to outsource certain tasks related to document acceptance and authenticity verification to external service providers. At the same time, no information is publicly available about potential contracts with such service providers, so it is impossible to fully assess how this mechanism will be implemented in practice. Such a solution itself also creates additional risks. If document reception and initial inspection are entrusted to a private external provider, and supervision mechanisms are not sufficiently clear and strict, there is a risk that instead of strengthening control, additional preconditions for increasing circulation of forged or dubious documents may be created. A significant drawback is also that it is not sufficiently clearly defined who exactly can act as an external provider, what qualification and security criteria it must meet, in which countries such service providers may be registered, and which state institution will ensure supervision and control of their activities. A similar problem is visible in the new Immigration Law regulation, which provides the possibility to outsource certain immigration-related tasks to external providers, but important questions about selection, responsibility, and supervision of such providers are not sufficiently detailed. 3. The report provides for the creation of various inter-institutional working groups tasked with ensuring information exchange on the latest document forgery methods, developing and coordinating appropriate countermeasures, and assessing possibilities to provide services with necessary technical equipment and make corresponding financial investments. However, in this case as well, proposed solutions are mainly aimed at managing existing or potential consequences of growing immigration, not at halting immigration itself or creating mechanisms to achieve the departure of existing immigrants. Thus, again, it is proposed to strengthen control over the ever-increasing number of immigrants and its consequences, not to address the issue of reducing the total number of immigrants in Latvia. 4. The report considers the possibility of concluding legal assistance agreements with countries from which a significant number of immigrants currently arrive in Latvia. The purpose of such agreements would be to ensure more effective information exchange about entrants, including their personal data and authenticity of submitted documents. It should be noted that with India and Bangladesh such agreements are currently not concluded, while with Uzbekistan the relevant legal assistance agreement is already concluded (Top 3 countries from which immigrants arrive in Latvia). A significant issue is the planned timeline – the assessment of possibilities is planned to be completed only by the end of 2027. This means that until a concrete solution is adopted and possibly implemented in practice, a considerable time may pass. Given the current immigration flow, a legitimate question arises – how many more immigrants will arrive in Latvia during this time. The report also suggests regularly monitoring the situation to assess, if necessary, the possibility of adding to the so-called 'black list' countries from which entry is automatically refused. However, no specific deadline is set for this measure. Thus, 'situation monitoring' can essentially continue indefinitely without creating a clear obligation to make a decision within a set timeframe on including specific countries in the list. In comparison, ASL proposes to already now add India to the list of countries whose citizens would be denied entry to Latvia. 5. The report provides for continuing raids, improving statistical accounting of forged document cases, and ensuring initiation of criminal proceedings. All this is necessary, but essentially characterizes measures already being taken under conditions of ever-increasing immigration. The more immigrants, the more raids, document checks, detected violations, and criminal proceedings. So, strengthening control of consequences, not solving the immigration problem itself. 6. The report proposes to assess the possibility of amending the Asylum Law, providing asylum seekers with the obligation not only to participate in procedural actions of the asylum procedure, but also to permanently reside in a specified place until the relevant decision is made. It is also proposed to assess the possibility of requiring asylum seekers to regularly register when they stay outside the asylum seeker accommodation center, with sanctions for non-compliance. In case of unauthorized absence, it is suggested to cancel the asylum seeker status request and expel the person from Latvia. This intention is understandable in itself, but the question arises – why are such measures not implemented already now? Why is a person who is in Latvia based only on a certificate issued by the State Border Guard about the initiation of asylum procedure not subject to specific movement or location restrictions that would allow the state to effectively control the person's location and thus promote public safety? No proportionality or human rights principles would be violated in this case if an asylum seeker were required to be reachable by the state and follow a certain location regime until a decision is made – similar to how a Latvian citizen is expected to be reachable and fulfill state-set obligations. 7. Significant questions also arise from the intention to assess which categories of TUA (temporary residence permit) recipients should be required to regularly register in person at PMLP or its service centers, to ensure that the person actually resides in Latvia and is thus entitled to apply for PUA (permanent residence permit). In this case, it would be justified to establish that the person themselves must prove continuous residence in Latvia to apply for PUA, rather than the state having to actively identify potential PUA recipients and verify which TUA holders actually continue to reside in Latvia. 8. The report emphasizes the need to clarify Latvia's higher education export goals, including setting priority target countries and stricter criteria for admission of foreign students. It also plans to test the English language skills of prospective students, with the State Education Quality Service providing practical English proficiency checks for foreign students. Thus, state resources are allocated to control foreign students' language skills, moreover checking not Latvian but English knowledge. In contrast, ASL's proposal is to require all immigrants to know the Latvian language (TUA-B2, PUA-C1). 9. It is planned to amend existing norms, establishing that the number of third-country students must not constitute a significant part of the total proportion of foreign students at a university. A significant question arises – what percentage is a 'significant part'? In the 2025/2026 academic year, there were more than 76,000 students in Latvia. The number of foreign students was approximately 12,000 or 15%. It is planned that students from other countries will not be allowed to exceed 50% of the total number of students. Regarding third-country students, it is established that they must not form a 'significant part.' Currently, students from India already exceed 6,000 or about half of all foreign students. So the question remains – how large is an 'insignificant part'? 10. It is planned that a student will have to separately obtain a work permit. Fine – a permit will need to be obtained. How could that stop or even reduce immigration from third countries? 11. Statistics on third-country workers in Latvia will be refined. Fine – but how could that stop or even reduce immigration from third countries? 12. A system for recording working hours of third-country nationals employed in Latvia will be developed, providing that both the inviting employer and the invited employee will have an obligation to record actual hours worked. Is working time recording not already mandatory? The employer must record the employee's actual working time, including overtime, and non-compliance can have legal consequences. If such requirements already exist, then it is unclear what exactly the new system will change regarding immigrants from third countries. If current regulations are not properly followed, the question also arises – why has this situation existed in practice until now, and how many sanctions for working time recording violations have been applied to employers and other responsible parties? 13. It is proposed that the State Labour Inspectorate monitor foreign job advertisements about work opportunities in Latvia to identify potential regulatory violations. Also in this case, the solution provides additional supervisory duties and thus additional burden and costs for public administration. The larger the number of immigrants, the more resources are needed for their control and supervision. Therefore, the question is appropriate – would a more effective approach be not to continually expand control mechanisms, but to significantly reduce the number of immigrants? 14. The report suggests creating a separate working group to eliminate information fragmentation between institutions overseeing the labor market and migration processes. Also in this case, the solution provides for the creation of a new working group, additional bureaucracy, and greater supervisory volume, rather than reducing the number of immigrants. So, an increasing number of immigrants creates ever new control mechanisms. 15. It is recommended to request quality statistical data from 'Bolt' and 'Wolt' on the actual hours worked by students and other couriers, as well as to develop an effective model for obtaining information on couriers' real employment volume. Also in this case, the solution is not aimed at reducing the number of immigrants or applying stricter sanctions in case of violations. Instead, additional information collection, new control mechanisms, and possibly another working group are provided. So – again growing bureaucracy to manage the consequences of growing immigration. 16. It is recommended, given that the capacity limits of Latvia's responsible institutions have already been reached at the current immigration volume, to set quotas for the total number of third-country citizens who can receive residence permits or long-term visas. However, it is not clearly understood what exactly these quotas would be and by what criteria they would be set, but from this point it becomes unequivocally clear that the goal is not to reduce the total number of immigrants in Latvia. 17. In case of an increase in illegal immigration, it is planned to increase the number of State Police officials involved in illegal immigration control measures, as well as improve their material and technical support. Here too, the solution provides increasing state resources and capacity to control growing immigration volume, rather than setting concrete measures aimed at halting such immigration. So, what actually lies beneath the loudly announced immigration restriction plan? From the above, it is concluded that it is not about halting or significantly reducing immigration. It is about how to better manage already existing and, also in the future, growing immigration. More statistics, working groups, monitoring, registers, control mechanisms, checks, and additional duties for state institutions. There are no concrete proposals on how to reduce the number of immigrants, make Latvia less attractive for uncontrolled labor entry, promote the departure of already arrived persons, or set clear and measurable immigration reduction goals. If state institutions' capacity has already reached limits, but the solution is even more working groups, control, statistics, and bureaucracy, then a legitimate question arises – is this plan really to restrict (I remind that 'restriction' still means increasing the number of immigrants) immigration or just an attempt to more effectively administer its consequences? Such an approach already exists in Western European countries, where mass immigration has become a heavy economic burden precisely because of such control needs. This plan should answer a simple question: what specifically will be the result – how many immigrants will leave Latvia. ASL answers this question with the 'ASL anti-immigration plan' – 90% of immigrants must leave within 4 years. If J. Dombrava's plan has no clear answer to this question, then it is difficult to call this document a real plan. Rather, it looks like a plan on how to manage ever-growing immigration and which was developed to simulate action before the Saeima elections. Given the composition of the commission (including Čulkova, Levrence, Zivtiņš), in which it was adopted, as well as the attitude of the head of government towards immigration, that is not surprising. But in that case, it must not be presented as a victory in immigration policy.
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