In a joint statement, Terre des Hommes together with its partner organization Bundesfachverband Minderträglichkeit und Flucht and Save the Children Deutschland, criticizes

While the draft law does contain some improvements overall, the organizations strongly warn against stricter regulations regarding unaccompanied minor refugees. Their criticism focuses primarily on proposed changes to age assessment procedures and restrictive residency requirements, including fines for unaccompanied minors. 

“A child is a child, regardless of where they come from. The proposed residency requirements, which are even to be punished with fines, discriminate against unaccompanied minor refugees compared to other children. This is professionally flawed and indefensible under child rights. Protection is not achieved through coercion, but through tailored support,” criticizes Annika Schlingheider of Terre des Hommes .

“The planned changes to age assessment contradict the European legal principle of ‘in case of doubt, presume minority’ – this principle must apply without restriction. Instead of expanding medical examinations, we need clear standards, effective legal protection and reliable procedures,” explains Lennart Scholz from the Federal Association for Minors and Refugees.

The organizations also criticize the underlying intention of the draft, which is to achieve savings in the billions. From a child rights perspective, the goal of cost reduction can never take precedence over the protection, participation, and individual support of children and young people.

Regarding the statement

Background:
In March 2026, the Federal Ministry of Education, Family Affairs, Senior Citizens, Women and Youth (BMBFSFJ) presented a draft bill for the First Act on the Structural Reform of Child and Youth Welfare (First Child and Youth Welfare Structural Reform Act – 1st KJHSRG), to which Terre des Hommes issued a statement. The next step in the legislative process is cabinet agreement before the draft is submitted to the Bundestag.