1. The Italian case: institutional framework Decree-Law No. 146 of 23 December 2013, converted with amendments into Law No. 10 of 21 February 2014, established the Italian National Guarantor for the rights of persons detained or deprived of liberty with the aim of strengthening the protection of the rights of persons subject to limitation of personal liberty, including foreign citizens who are the recipients of an expulsion order pursuant to the rules contained in the Consolidated Act on Immigration (Legislative Decree No. 286/98) and subjected to forced return operations. The European Directive for returning illegally staying third-country nationals (2008/115/EC) requires States to provide “an effective system for monitoring forced returns” (Article 8, paragraph 6). This Directive does not prescribe in detail how national monitoring systems should be organized, but leaves a wide margin of discretion to Member States. However, the Return Handbook established by the Commission Recommendation (EU) 2017/2338 of 16 November 2017 sets out common standards to be used by Member States’ competent authorities when carrying out return related tasks (OJ L 339, 19.12.2017, pp. 83-159) providing some guidelines in this regard and in particular:  the need to monitor all phases of return operations;  the recommendation to appoint independent organizations/experts for monitoring;  the inadequacy, for the purposes of monitoring, of judicial remedies in individual cases or of national systems for monitoring the efficiency of national return policies;  the obligation to ensure that a monitoring system is overall and fully operational;  the possibility of implementing a sample monitoring system, on condition the overall efficiency of the monitoring system is guaranteed. In Italy, article 7 of Decree-Law No. 146 of 23 December 2013 (converted with amendments into Law No. 10 of 21 February 2014) attributes to the National Guarantor for the rights of persons detained or deprived of liberty the task of ensuring that the custody of the persons subjected to the limitation of personal liberty is implemented in accordance with the national standards and international human rights conventions ratified by Italy. Since the early months of 2016, the National Guarantor also operates as a national and independent body for monitoring forced returns, having been designated by the Presidency of the Council of Ministers as a national monitoring body precisely in view of its being an independent body that reports mainly to Parliament and by virtue of its institutional mandate, that relates to deprivation of liberty in general. The assignment of the task of monitoring to the Guarantor takes place in the context of a particular historical phase in Italy. In fact, if on the one hand, starting from 2017, there has been a decrease in arrivals (in 2018 the flow to Italy decreased by 80% compared to the same period of 2017: in fact, from 1 January to 5 November 2018, 22 thousand migrants landed on the Italian coasts – while in 2017 there were over 112 thousand migrants arriving), on the other hand there has been growing attention on the issue of repatriations and returns. According to the elaborations carried out by the Guarantor of the data provided by the Public Security Department – Central Directorate for Immigration and Border Police, between 2015 and 2018, forced returns from Italy increased from 5,505 to 6,398 (5,817 in 2016; 6,514 in 2017).