Charlie Magri, Dr. Ted R. Bromund, and Sandra Grossman have published a new article in the International Enforcement Law Reporter (IELR, Volume 42, Issue 4). Titled “Commission for the Control of INTERPOL’s Files Acknowledges and Addresses Delays,” the piece surveys the CCF’s 2024 Annual Activity Report, analyzes the procedural reforms announced in early 2026, and identifies the institutional questions that will define the CCF’s trajectory over the next two years.
The 2024 Annual Activity Report
The CCF received 2,586 admissible submissions in 2024. The rate of increase over 2023 slowed to 4 percent, following a period of steady growth that has more than doubled the caseload since 2018, when 1,265 admissible requests were received. The article notes that this growth has been driven in part by the expansion of a specialized legal community focused on INTERPOL practice.
Of the 539 deletion requests decided by the CCF, data in 272 were found non-compliant. Another 50 requests were decided in favor of the applicant on the grounds of total lack of cooperation by the requesting state. That left 217 requests (roughly 40 percent) in which the data was found compliant. While 40 percent may appear low, the authors observe that it represents an increase over the 26 percent found compliant in 2022 and 32 percent in 2023, driven partly by improved cooperation rates among member states.
The more concerning figure is the delay rate. Thirty percent of deletion requests in 2024 were not completed within nine months, up from 15 percent in 2023. CCF Chairperson Teresa McHenry described reducing these delays as “among the highest priorities” of the Commission, while acknowledging that the time required to train new staff and develop new technologies means the situation is likely to worsen before it improves.
Procedural Reforms
The article documents three major announcements made by the CCF in the months following the 2025 General Assembly in Marrakech.
First, the CCF announced a pilot project for 2026 aimed at distributing the decision-making workload more evenly across the year. The pilot features more online case reviews by CCF members, expanded delegation of authority to the Rapporteur and Chairperson for non-complex cases, longer two-week sessions, and the possibility of a fourth session in December if necessary.
Second, the CCF launched its new online portal on 26 March 2026. The portal is now the sole channel for submissions: emails and postal filings are no longer accepted. It allows applicants and their representatives to submit, track, and manage all aspects of a request. The authors note that the portal responds directly to the volume of administrative correspondence (over 82,000 emails received in 2024) and the growing complexity of submissions. For a detailed analysis of the portal’s practical implications, see our earlier article: What the CCF Portal Changes in Practice.
Third, the CCF confirmed that all seven member positions will be filled at the next General Assembly, to be held in Hong Kong on 17 to 20 November 2026. The five-year terms of all current members expire on 11 March 2027. Some or all could be re-elected for an additional three-year term, or the General Assembly could elect new members entirely.
The CCF Elections
The article treats the upcoming elections as the single most consequential event on the CCF’s calendar. The current membership has overseen a substantial increase in the professionalism of the Commission, and the election could put that progress at risk. The authors call on democratic member states to work together to ensure that this does not happen. They also note that the CCF’s openness in announcing the election process well in advance is new and commendable.
The Statute Review
The CCF is in the middle of a multi-year review of its governing Statute, a process that has already produced three public calls for input and resulted in the amendments adopted at the 2025 General Assembly (analyzed by the same authors in IELR Volume 42, Issue 2). The third call for input, covering Articles 3, 34, and 35, closed on 11 March 2026. The review is expected to continue through the 2026 and possibly 2027 General Assemblies. The authors quote Chairperson McHenry’s recognition that “everyone agrees with the overall goals to improve the Statute without compromising CCF independence” while adding that “these are hard issues, and there may not always be agreement.”
Facing a Red Notice or CCF proceeding?
Otherside is a specialist law firm dedicated exclusively to INTERPOL and CCF matters, founded by a former CCF Legal Officer. If you need assistance with a deletion request, access request, or provisional measures, contact us for a confidential review.
