Complementary Protection after Decree-Law No. 20 of 2023: Constitutional and International Obligations as an Autonomous Legal Basis for Protection
A Comment on the Decision of the Florence Territorial Commission for International Protection – Livorno...
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Complementary Protection after Decree-Law No. 20 of 2023: Constitutional and International Obligations as an Autonomous Legal Basis for Protection
A Comment on the Decision of the Florence Territorial Commission for International Protection – Livorno Section, 10 July 2026
Fabio Loscerbo
Abstract
The decision adopted on 10 July 2026 by the Florence Territorial Commission for International Protection – Livorno Section makes a significant contribution to the interpretation of complementary protection following the amendments introduced by Decree-Law No. 20 of 10 March 2023. Although the Commission rejected the application for refugee status and subsidiary protection, it found substantial grounds for concluding that the applicant’s removal would be contrary to Italy’s constitutional and international obligations. Protection was recognised on the basis of the combined assessment of personal vulnerability, origin from a poor rural environment, limited education, responsibilities towards
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