Excluding in the Name of Integration: the Keren case and integration duties on trial - again

In Keren the Grand Chamber of the Court of Justice of the EU upheld the possibility for Member States to impose civic integration examinations on the beneficiaries of international protection, while limiting the modalities, costs and potential penalties of such requirements. This commentary reviews the factual and legal background of the case, the AG’s Opinion, and the Court’s judgment. It shows that the ruling largely reiterates principles developed in earlier case law on integration obligations—under both EU migration law and the EU-Turkey Association Agreement. While this continuity may appear legally coherent, the commentary argues that Keren merited a different outcome, one that rejects integration obligations altogether, regardless of the recently adopted 2024 Qualification Regulation which did not apply to the case. This is particularly significant in light of the growing instrumentalisation of integration requirements as mechanisms of exclusion: tools used to target those who—in Zygmunt Bauman’s terms—are cast as "strangers" for aligning insufficiently well with dominant cultural and social norms.