What the CCF Portal Changes in Practice: A Guide for Practitioners and Applicants

On 26 March 2026, the Commission for the Control of INTERPOL’s Files (CCF) launched a dedicated online portal for the submission of requests. On the same date, the CCF published its first Portal User Guide for Applicants (the “User Guide”) and adopted a revised set of Operating Rules, replacing those last amended on 27 June 2024. Together, these documents reshape the front end of the CCF process. This article sets out what has changed, what the amendments mean in practice, and what practitioners and applicants need to do about it.

Email Is Dead

This is the starting point. The portal is not an additional option; it is the only option. Rule 25 of the amended Operating Rules requires all submissions to be made through the portal. The User Guide confirms that the CCF will not take into consideration any information or documents sent by email or postal mail, unless it has authorized alternative means under Rule 25(2) in exceptional circumstances.

In practical terms, this means every firm, every NGO, and every self-represented applicant filing a new request must use the portal. For cases already pending before the CCF, the position is different. The CCF’s FAQ confirms that requests submitted before the portal launched will be handled under the previous procedure, and applicants do not need to take any action. The CCF may decide to migrate ongoing cases to the portal; if so, applicants will be advised.

For new requests, all post-submission communications must go through the portal’s “Send Message” function. Emails from the CCF are sent from an unmonitored no-reply address. Replies to those emails will not be received. Any practitioner filing a new request should take note: once submitted, the portal is the only channel.

The 10-Page Argument Limit

Rule 30(8) of the amended Operating Rules introduces a hard cap on the summary of arguments for correction/deletion and revision requests: 10 pages maximum. This rule is entirely new. The previous Operating Rules imposed no page limit.

The User Guide specifies what those 10 pages must contain: a factual outline, legal arguments organized by reference to the INTERPOL rules allegedly violated, and a clear summary of the request’s purpose. Optional content includes background on the applicant, references to appendices, information on linked requests, and any restrictions vis-a-vis data sources.

The 10-page limit is an admissibility condition, not a guideline. A submission that exceeds it risks being declared inadmissible before the merits are reached. There is no discretionary tolerance built into the rule.

The 20-Appendix Cap

The User Guide confirms that submitters may upload a maximum of 20 appendices. Each must be clearly labelled, with file names starting with the appendix number, and referenced in the summary of arguments.

For cases with extensive documentary records (court judgments, country reports, expert opinions, media articles, corporate filings, medical evidence, correspondence), selecting only 20 exhibits requires strategic judgment. The question is no longer “what evidence supports my arguments?” but “what are the 20 most impactful documents the Commission needs to see?”

The User Guide provides one partial escape valve: where information is published on a freely accessible website, the URL should be cited in the arguments document rather than uploaded as an appendix. The PDF version should not be included. However, sources behind a paywall or requiring login must be uploaded as PDFs. This means publicly available country condition reports, news articles, and legal databases can be cited by URL, preserving appendix slots for documents that exist only in the case file.

If a submitter needs more than 20 appendices, the User Guide says they should list and justify the additional documents, and the Commission will advise. This suggests the ceiling has some flex, but it should not be treated as a routine workaround. Filing 20 appendices and then requesting permission for 15 more will not reflect well on the submission.

No Video, No Audio: Written Procedure Only

The User Guide states that video and audio submissions are not considered during the study of a request. The procedure before the CCF is written. Only transcripts of pertinent extracts may be taken into consideration.

The practical implications are immediate. Any case that relies on recorded testimony (witness interviews, client statements, media broadcasts, recordings of judicial proceedings) must now include written transcripts of the relevant passages. The transcript becomes the evidence, not the recording.

Preemptive Requests: An Open Question

The term “preemptive request” has generally been understood to refer to requests addressed to the Commission in which the requester asks INTERPOL not to process any future data in its files, even when there are no data currently in INTERPOL’s files, on the basis that doing so would violate the Organization’s rules. The CCF Statute itself does not use the term, but the concept was recognized and described on INTERPOL’s public website.

Under the previous practice, as set out on the CCF page of the INTERPOL website, the procedure worked as follows. The requester could provide information supporting the contention that processing such data would violate INTERPOL’s rules. Upon receipt, the Commission would submit the request and any accompanying information to the INTERPOL General Secretariat for its information and appropriate action, so that the material could be considered during future compliance reviews if a request for police cooperation was received from the requesting state. The Commission would inform the requester that the submission had been provided to the General Secretariat. However, the Commission would take no further steps in relation to reviewing the data unless the requester subsequently submitted a separate application for access to and/or correction or deletion of data, at which point the Commission would review the application in accordance with its rules and procedures.

In other words, the preemptive request was not a full adjudicatory procedure. It was a mechanism to place arguments and evidence on file with the General Secretariat in advance of any data being published, so that the material would be available during the compliance review. The Commission acted as a conduit, not as a decision-maker, at the preemptive stage. The substantive review only began if and when the requester filed a separate correction/deletion request after data appeared in INTERPOL’s system.

This information has now been removed from the CCF page of INTERPOL’s public website. The new portal offers three request types: Access, Correction/Deletion, and Revision. None of these maps onto a preemptive request. A preemptive filing is not an access request, it is not a correction/deletion request in the traditional sense (there is no published notice or diffusion to challenge), it is certainly not a revision application.

The User Guide is silent on preemptive requests. It does not mention them, does not explain how they should be filed under the portal’s three-category structure, and does not indicate whether they remain available.

This gap matters. Preemptive requests served a specific function: they allowed an individual who had credible intelligence that a requesting state intended to issue a Red Notice or diffusion to place arguments on file before the data entered INTERPOL’s system. In cases involving political persecution, retaliatory prosecution, or known patterns of abuse, having material on file with the General Secretariat before the compliance review was a practical safeguard. The disappearance of the preemptive category from both the portal structure and the public-facing CCF documentation raises the question of whether this mechanism still exists, and if so, how it should be invoked.

The most plausible approach may be to file a deletion request through the portal, framed in anticipation of data being published, and use the arguments document to explain the preemptive nature of the filing. Whether the CCF will accept this approach is unclear.

Access Requests Are Now Straightforward

Under the previous system, access requests were typically submitted by email with a covering letter, a power of attorney, and identity documentation. Some practitioners filed detailed covering letters setting out the basis for the request and any concerns about data processing.

The portal simplifies this. Access requests do not require a cover letter or a summary of arguments. The structured fields in the portal are sufficient. The submitter provides the applicant’s identity information, selects the data type, and submits. The Guide states that further information may be indicated in the portal’s fields, but there is no obligation.

This is a welcome simplification. It reduces the preparation time for access requests considerably and removes any ambiguity about what documentation is required at the access stage.

Submitters are invited (but not required) to check whether any publicly available Red or Yellow Notices appear on INTERPOL’s website concerning the applicant, and to indicate this. The Guide recalls that most Red Notices are restricted to law enforcement and are not publicly visible, so the absence of a public listing does not mean no data exists.

Revision Applications: The Two-Page Threshold

The portal enforces a staged process for revision applications under Article 42 of the CCF Statute. At the initial stage, submitters may attach only one document: a two-page summary describing the newly discovered facts.

Two pages. No arguments document. No appendices.

The CCF then reviews the two-page summary. Only if the Commission requests further documents may the submitter provide a full summary of arguments (subject to the 10-page limit) and appendices (subject to the 20-appendix cap). The application must be filed within six months of the discovery of the new facts.

This is a genuine gatekeeping mechanism. The two-page summary must accomplish three things on its own: identify the newly discovered facts with precision, explain why those facts could have led the Requests Chamber to a different conclusion on the original request, and establish that the facts were not available during the original proceedings. If the two-page summary does not persuade the CCF that a full review is warranted, the application does not proceed. There is no second bite at this stage.

Practitioners filing revision applications should treat the two-page summary as the most important document in the case. It is not a formality or a preliminary filing. It is the threshold. Draft it with the same care and precision as a final submission.

One Request Type Per Submission: No More Combined Filings

The portal requires submitters to select one request type per submission: Access, Correction/Deletion, or Revision. Only one can be selected. If an applicant needs both an access request and a correction/deletion request, two separate submissions must be filed.

Under the previous email-based system, it was common practice to submit a combined access and deletion request in a single package, often with a single covering letter introducing both. That practice is no longer possible.

The portal allows requests to be linked through the “Link” section, so the CCF is aware of related filings. Linked requests can relate to the same applicant, the same criminal case, or members of the same family. If submitting linked requests simultaneously, the Guide advises indicating in the first submission that a further request “will follow.”

There is a critical point: even where requests are linked, the CCF treats each independently. Arguments and evidence filed in one request cannot be relied upon to support a separate linked request. Each submission must be self-contained. This means that if evidence is relevant to both an access request and a correction/deletion request, it must be included in both submissions separately.

Power of Attorney: What Practitioners Must Get Right

The Guide sets out several requirements for powers of attorney that practitioners need to internalize.

The power of attorney must be signed by the applicant. A power of attorney signed by the lawyer, designating themselves as representative, is not accepted. The Guide is explicit on this point. In cases where the client is detained, in exile, in hiding, or otherwise difficult to reach, the signed power of attorney must still be obtained before the portal submission can proceed. There is no workaround, no provisional filing mechanism, and no exception.

Where no expiry date is indicated, the CCF will deem the power of attorney valid for two years from the date of the applicant’s signature. Cases that are expected to run longer should either include a specific longer validity period or have the power of attorney renewed before expiry.

The CCF provides a template power of attorney allowing the designation of one main representative and up to two additional contacts within the same firm or organization. All three can receive correspondence from the CCF. Firms should use this to ensure that case communications reach the right people, particularly where multiple lawyers are working on the same matter.

Changing Representative: Consequences Practitioners Must Explain to Clients

The procedure for changing representative mid-case is spelled out in the User Guide, and it carries real risks.

If an applicant wishes to change representative, the new representative must submit a fresh request via the portal with a new power of attorney signed by the applicant. The new representative automatically becomes the sole point of contact.

The new representative must make a binary choice: either the CCF should continue to consider the former representative’s submissions, or the new filing should rescind and replace them entirely. This is not a soft transition. If the new representative opts to rescind, the former submissions are effectively withdrawn. The record starts fresh. If they opt to continue, both sets of submissions remain on file.

The new representative may also request that the study of the existing request be suspended while they prepare new submissions. This buys time, but it extends the case timeline.

There is a further mechanism that requires careful client management. If an applicant with an ongoing request filed through a representative contacts the CCF directly (by submitting a request through the portal in their own name), the CCF will treat this as an instruction that the applicant is now the sole point of contact. The former representative will be notified. This is automatic: There is no confirmation step.

The practical implication is clear. Clients must be told, in writing, before proceedings begin, that any direct contact with the CCF could result in the termination of the representative’s mandate. Engagement letters should address this point expressly. A client who contacts the CCF out of frustration, impatience, or confusion may inadvertently sever the lawyer-client relationship for the purposes of the CCF proceedings, with no mechanism to reverse it other than filing a new request to re-establish representation.

One Draft at a Time

The portal allows submitters to save one draft at a time. Only one. For practitioners managing multiple clients, this means drafts for different cases cannot be worked on in parallel within the same portal account. Each draft must be completed and submitted (or discarded) before the next can begin. Filing schedules for high-volume practices will need to account for this limitation.

What Applicants Need to Know

For applicants filing on their own behalf, without legal representation, the portal is designed to be navigable. The form adapts dynamically, hiding sections that are not relevant. Mandatory fields enforce the minimum admissibility requirements. Dropdown menus structure the responses.

That said, self-represented applicants should be aware of several points that may not be obvious from the portal interface alone.

The 10-page argument limit applies to everyone, not just lawyers. Applicants filing their own correction/deletion requests must comply with the same format requirements.

The 20-appendix cap applies equally. Selecting which 20 documents to include requires judgment about what will be most persuasive to the Commission, not simply attaching everything available.

All documents must be in Arabic, English, French, or Spanish. Documents in other languages must be translated. This includes appendices.

The portal is the only way to communicate with the CCF. After submission, all further messages must go through the portal’s “Send Message” function. Emails to the CCF will not be received.

Summary

The portal launch is the most significant procedural reform at the CCF in years. It standardizes the intake process, imposes discipline on submissions, and raises the bar for what the Commission will accept at intake. For practitioners, the key adjustments are: restructure arguments to fit 10 pages, select exhibits to fit within 20 appendices, transcribe any audiovisual evidence into writing, brief clients on the consequences of direct contact with the CCF, and clarify the status of preemptive requests before filing.

For applicants, the portal is accessible but the requirements are exacting. The format constraints apply equally to represented and self-represented individuals. Preparation matters more than it ever has.

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Charlie Magri is the founder of Otherside, a specialist law firm dedicated exclusively to INTERPOL and CCF matters. He is a former Legal Officer at the Secretariat to the Commission for the Control of INTERPOL’s Files.