CoMiRa / News

Decree 646/2025: full regulation of the Refugee Law

Published 11.09.2025

On 10 September 2025, Decree 646/2025 was issued and later published in the Official Gazette of the City of Buenos Aires. It approves the regulation of Law 26.165 on the recognition and protection of refugees. The regulation aims to operationalize a legal standard that had lacked full executive rules and to create a clearer and faster process for assessing asylum claims.

BUENOS AIRES — The Argentine government has officially enacted Decree 646/2025, which “approves the regulation of Law No. 26.165 and its amendments.” According to the text, the decree includes the following key points:
• Issued on 10 September 2025 and published in the Boletín Oficial on 11 September.
• Repeals the previous regulatory decrees (No. 251 of 1990, No. 942 of 1995 and No. 102 of 2007).
• Seeks to close gaps in the application of the Refugee Law: the “lack of concrete procedures in the application of Law No. 26.165 and its amendments caused serious delays and legal uncertainty for both applicants and the administration.”
• Confirms that the competent authority is the Comisión Nacional para los Refugiados (CONARE), sets clear timelines and procedures (details in the annex).
• Aims to ensure more expeditious access to refugee status procedures, strengthen safeguards, and clarify cessation and exclusion rules.

What this means in practice:
• The refugee status procedure now has an operational regulatory basis, which should reduce open-ended waiting periods.
• Time limits are set; for example, when initiating cessation, the person must be summoned to an interview within 5 days of notification, and a decision should be issued within 60 days.
• Outdated decrees are repealed, improving legal clarity.
• Administration becomes more institutionalized under the new framework.
• While rights under the law remain, bureaucratic steps and timelines should become more transparent and predictable.

Important notes:
• Implementation will depend on resources allocated to the competent bodies and the speed of rollout.
• Backlog cases under Law 26.165 may still follow prior procedures for a transitional period.
• Applicants should monitor how CONARE and migration offices apply the new rules in practice, as annexed details may be challenging to implement.