The Limits of Mandatory Integration Enforcement for Third-Country Nationals: Reflections After Case C-158/23 ( Keren ) and the Entry into Force of the Qualification Regulation

This article examines the implications of Case C-158/23 ( Keren ), decided by the Court of Justice of the European Union in February 2025, for the lawfulness of mandatory civic integration measures imposed on beneficiaries of international protection and other third-country nationals under EU migration law. Written at the moment of entry into force of the Qualification Regulation (EU) 2024/1347, the article situates the Keren judgment within a broader line of case law on integration measures, starting from K&A and P&S , and analyses its consequences for national integration policies beyond beneficiaries of international protection. The article argues that the Court established several key limitations on mandatory integration: Measures must be provided free of charge, target language levels may not exceed an elementary standard, financial sanctions may only be imposed in exceptional circumstances, and individuals who are already effectively integrated into the host society must be exempted from further obligations. The article further contends that these requirements extend, mutatis mutandis , to other groups of third-country nationals subject to integration conditions, particularly family migrants. It concludes that Member States must guard the limits of coercive and formalistic integration frameworks and recognise real, rather than merely formal, integration.