INTERPOL Red Notice Deletion Delays: What the CCF’s 2024 Report Means for Applicants
Make it stand out
By Roger Sahota, Partner, Berkeley Square Solicitors
Applicants seeking the deletion of an INTERPOL Red Notice or Diffusion should now be prepared for longer delays before the Commission for the Control of INTERPOL’s Files (CCF) reaches a decision.
How long are CCF deletion applications taking?
The CCF’s Annual Activity Report for 2024 confirms that, although the Commission continues to process a record number of requests, it is struggling to meet the statutory timetable for deletion applications. Under Article 40 of the CCF Statute, the Requests Chamber is required to decide requests for correction and/or deletion within nine months of the request being declared admissible. That period may be extended where the circumstances of the case justify it, but any extension must be reasonable and explained in the decision.
In 2024, 30% of deletion requests took more than nine months to complete. This represents a significant deterioration from 2023, when 15% of deletion requests exceeded the nine-month period. The CCF has not published an average completion time for those cases which fell outside the nine-month target, meaning applicants are left with little certainty as to how long delayed cases may ultimately take.
For individuals facing the practical consequences of challenging a Red Notice these delays have a real effect on liberty, family life and business. A pending CCF application does not prevent arrest at a border, disruption to travel, reputational harm, banking difficulties or wider commercial consequences.
Why are CCF deletion applications taking longer?
The principal reason appears to be volume. In 2024, the CCF received 2,586 new admissible requests, the highest number ever recorded. This figure includes access requests, deletion requests and applications for revision. The CCF itself attributed the increase in part to the growing focus on international cooperation and data-protection standards.
The increase in filings is also likely to reflect the growing awareness among lawyers, NGOs and affected individuals that INTERPOL data can be challenged. Red Notices and Diffusions are no longer viewed as inviolable.
A further source of delay is the consultation process. Under Article 34 of the CCF Statute, if further information is required to examine a request, the Requests Chamber may seek information or clarification from the source of the data, usually the requesting States National Central Bureau (“NCB”), and/or from INTERPOL’s General Secretariat. Article 35 also governs communication of information and provides that, before disclosing information, the CCF must consult the owner of that information, namely the applicant or the source of the data.
In practice, this means that where a deletion application challenges the conduct of the requesting state, the CCF may need to obtain and consider information from that state before it can reach a final view. Where the NCB is slow to respond, provides incomplete answers, or refuses to cooperate, the applicant can be left waiting.
At BSQ, we frequently see this problem in politically sensitive Red Notice cases, particularly those involving allegations of fraud, corruption or economic crime where the applicant maintains that the request is being used for an improper political or strategic purpose. We have also seen delays arise in cases involving requests from China, where submissions often require careful analysis of Article 3, fair trial concerns, proportionality and the reliability of the underlying allegations.
What do 2024 deletion figures show?
The 2024 report gives a useful indication of how deletion applications are being decided.
The CCF closed 1,077 deletion requests in 2024. Of those, 703 were admissible requests involving applicants who were actually subject to data in INTERPOL’s files. In 164 cases, the data was deleted by the NCB source or by the General Secretariat before the CCF issued a decision. For the remaining 539 deletion requests decided by the CCF, the outcomes were as follows: 217 were found compliant with INTERPOL’s rules; 272 were found non-compliant; and 50 were found non-compliant because of a total lack of cooperation from the NCB source.
Those figures are striking. A finding of “total lack of cooperation” in 50 cases demonstrates that some requesting states continue to fail to engage properly with the CCF process. For applicants, this can be significant. A state which seeks to maintain an international police alert should be expected to justify the basis for that alert when challenged.
At the same time, the number of cases found compliant appears to have increased when compared with recent years. The source material notes that compliant findings rose from 26% in 2022 to 32% in 2023 and approximately 40% in 2024. One possible explanation is improved cooperation by member states, although each case will continue to depend on its own facts, evidence and legal submissions.
What reforms has the CCF announced?
The CCF has acknowledged the problem and has announced procedural changes designed to reduce delay.
On 26 March 2026, the CCF announced that all requests to the CCF must be submitted through its new secure online portal. Email and postal applications are no longer accepted unless exceptional circumstances justify another method. The portal allows applicants and authorised representatives to submit requests, track their status, access communications and supporting documents, and consult decisions. (interpol.int)
This is a major practical change for lawyers and applicants. It should, in principle, reduce administrative delay and improve case management. It also reflects the sheer volume of correspondence now handled by the CCF.
The CCF has also indicated that it is reviewing its procedures and seeking to manage decision-making more evenly throughout the year. Any reform which improves efficiency is welcome. However, applicants should not assume that the new reforms will immediately cure the underlying problem. The CCF’s caseload is increasing, cases are becoming more complex, and many applications depend on the responsiveness of requesting states.
What should applicants do while a deletion request is pending?
The message for applicants is clear: Red Notice deletion applications should be prepared carefully and as early as possible.
Where a Red Notice is politically motivated, based on unreliable allegations, disproportionate, abusive, or inconsistent with INTERPOL’s rules, the application should be supported by detailed evidence from the outset. Delay at the CCF makes it even more important that the initial filing is complete, focused and properly structured.
Applicants should also consider whether urgent interim measures are required. In appropriate cases, it may be possible to seek provisional measures, including the temporary blocking of data, while the CCF considers the deletion request.
The CCF remains an essential safeguard against the misuse of INTERPOL’s systems. However, the 2024 figures show that applicants should be realistic about timescales. A nine-month decision is no longer something that can be assumed. In a significant minority of cases, particularly complex or politically sensitive cases involving China, the process may take longer.
Specialist advice on INTERPOL Red Notice deletion
BSQ’s INTERPOL team advises individuals who are subject to Red Notices, Diffusions and other INTERPOL alerts, particularly where issues arise concerning political motivation, abuse of process, economic crime allegations or extradition risk. If you require advice and assistance in relation to an INTERPOL Red Notice or Diffusion, please contact our London office on +44 203 858 0851.
About the Author
Roger Sahota is a specialist INTERPOL Red Notice solicitor with extensive experience in CCF deletion applications, including politically sensitive cases and requests originating from China. BSQ regularly advises on Red Notices, Diffusions, Article 3 challenges, proportionality, fair trial concerns and allegations of economic crime.