Mastodawn

Migrating to the EU

https://rz01.org/eu-migration/

rz01.org

pschastain 5d ago

How comfortable are you guys with the fact that EU countries allow prosecutors and sometimes even police officers to issue their own search warrants without meaningful judicial review? Some EU courts will not exclude illegally obtained evidence either, so challenging the warrant later on will be pointless.

Oh, and you might be in a reasonable EU country and still be hit with an EIO from one of the unreasonable countries. This is especially concerning given recent ECJ rulings increasingly directing courts in receiving nations to blindly defer to the requesting party when dealing with EAWs, EIOs and similar.

Worth considering when hosting in the EU.

Valid question, which must be put in the context of US-based providers willingly satisfying US out-of-jurisdiction search requests for EU data without even letting the EU know about it. (And when the providers are not willing, they can be forced by U.S. Cloud Act)

https://www.forbes.com/sites/emmawoollacott/2025/07/22/micro...

Microsoft Can't Keep EU Data Safe From US Authorities

Microsoft has admitted to a French senate hearing that it can't protect EU data from U.S. government snooping.

Forbes

throw0101c 5d ago

> How comfortable are you guys with the fact that EU countries allow prosecutors and sometimes even police officers to issue their own search warrants without meaningful judicial review?

(IANAL.) This was reviewed by the courts themselves:

> The CJEU confirmed that the Belgian, French and Swedish prosecutors were sufficiently independent from the executive to be able to issue EAWs. […]

> […] Public prosecutors will qualify as an issuing judicial authority where two conditions are met: […]

> 2. Second, public prosecutors must be in a position to act in an independent way, specifically with respect to the executive. The CJEU requires that the independence of public prosecutors be organised by a statutory framework and organisational rules that prevent the risk of prosecutors being subject to individual instructions by the executive (as was the case with the German prosecutor). Moreover, the framework must enable prosecutors to assess the necessity and proportionality of issuing an EAW. In the French prosecutor judgment, the CJEU specifically indicated that:

* https://www.fairtrials.org/articles/legal-analysis/can-belgi...

The question that the OP asks is fair enough, but there's a lot of subtly and 'low-level' details on how things operate compared to the high-level question that is being asked. Also depends on where the OP lives and what he's used to: common law (UK/US/CA/etc) and civil law procedures and laws are (AIUI) quite different.

Can Belgian, French and Swedish prosecutors issue European Arrest Warrants? - Fair Trials

Fair Trials

For anyone wondering:

EAW = European Arrest Warrant

EIO = European Investigative Order (basically lets different jurisdictions demand information from each other)

CJEU = Court of Justice of the EU (think of it as a supreme court)

Also IANAL: I Am Not A Lawyer. If you really want to guard yourself from a legal standpoint, write the full sentence. "IANAL" could mean anything.

That being said, I am not a lawyer, I am not a legal professional, this is not a legal advice.

Sweden is a country like this. It is just the way it is here. It can be abused, sure. But all things considered, I much rather have my things hosted here than in the US.

pschastain 5d ago

Yeah, but you also have Hungary who can decide to do things the same way they're done in Sweden and Finland.

In Hungary, sure. But each country has its own jurisdiction.

microtonal 5d ago

So don’t host your stuff in Hungary?

Yeah I think this basically answers this entire sub-thread

pschastain 5d ago

Hungary can send an EIO to France or Germany, and the consistent trend has been to reduce the ability of executing states to review these requests.

There’s a concerning trend of EIOs issued by Hungary being enforced in France and Germany? What would be an example of this?

pschastain 5d ago

This is the best I can give you off the top of my head, but look at which countries are the most active in eurojust :) https://www.eurojust.europa.eu/ar2020/data-annex

An LLM can probably find some better links though.

Data Annex

Eurojust

I think you might be missing the ‘concerning’ part. Which specific cases are concerning? I don’t find it inherently concerning that people can’t escape justice by crossing the Hungarian border, Bonnie and Clyde style.

pschastain 5d ago

Oh no, that's totally up to you. If you're happy with the courts in your country not being able to review the requests sent from Hungary, that's cool. Without transparent judicial review, how could we even know if the cases are concerning?

EIOs are subject to review by the recipient state. It seems that you can’t point to a single relevant example of a concerning EIO from Hungary.

pschastain 5d ago

"Subject to review" means little more than "is the form filled correctly?", it certainly does not mean second-guessing by the courts in the executing state.

Like, yeah, your EIO will be rejected if you don't tick any of the crime-category boxes in the form.

ApolloFortyNine 5d ago

Too explicitly spell it out, op is saying here that if any one of the 27 countries in the EU decides you are breaking one of their laws, they can have 1 of the other 26 enforce an EIO.

pschastain 5d ago

Which would be perfectly fine if your local jurisdiction could still properly review those foreign requests.

EIOs are subject to a dual criminality requirement. So it’s not as if arbitrary Hungarian laws can be applied in France via EIOs. And of course, we all know this is not happening, which is why we get radio silence from the people who are ‘concerned’ about this whenever specifics are requested.

pschastain 5d ago

>EIOs are subject to a dual criminality requirement

Dual criminality requirement only applies to non-Annex D crimes. Which is... not many crimes. You seem awfully confident for someone so ill-informed.

>And of course, we all know this is not happening

How would you know that it isn't happening? EIOs are not public!

Annex D is a list of things that are crimes pretty much everywhere.

Not sure what to make of the claim that Hungary might theoretically be enforcing Hungarian law in France. It seems surprising that no-one has noticed any specific consequences of this that you can point to.

The EIO is mostly just a formalization and standardization of a bunch of ad-hoc processes that were already in place. Law enforcement agencies in different European countries do try to assist each other, on the whole.

pschastain 5d ago

What you're missing is the erosion of the ability of the executing states to say things like "hey this is sketchy, we think this crime might not have happened", "hey the police department in this particular city is notoriously untrustworthy", or "hey this prosecutor is widely known in the local press to be corrupt and owns a collection of ferraris".

Now foreign authorities are trusted by default and significant parts of their reasoning are not subject to review, that's bad.

Sure, those EIO will be held if Hungary starts applying EIO that it got (e.g. for former Ministry of Justice of Poland which awaits trail, he sits comfortably in Hungary).

Let's hope elections there will change Orban into something saner.

>How comfortable are you guys with the fact that EU countries allow prosecutors and sometimes even police officers to issue their own search warrants without meaningful judicial review?

This is a hilarious 'just asking questions' concern that doesn't address the complete 180 in direction the US is taking and descending in to authoritarianism while moving against the world order it primarily helped build post WWII while threatening other liberal democracies like Canada and Denmark with invasions.

It's a complete false equivalence. ICE agents have straight up murdered two US citizens in broad daylight without consequence and you're querying the nature of some search warrants in the EU.

aleph_minus_one 5d ago

> the complete 180 in direction the US is taking and descending in to authoritarianism

A similar (though currently a little bit less marked) trend can also be observed for the EU and EU countries.

>(though currently a little bit less marked)

Again this is a false equivalence, 'a little less marked' isn't close to imparting the true state of things and to be honest a little disingenuous.

The EU is not in full motion to dismantle democracy across her 27 states. The US should it not turn this around in the midterms is finished as a liberal democracy.

So 'ah yes but Hungary' doesn't persuade me even though I'll concede it's a problem for the EU. If Tisza is elected in April, Hungary will be on course to turn things around. So you're comparing 1 out of 27 to 50 out of 50 states.

sunaookami 5d ago

>The EU is not in full motion to dismantle democracy across her 27 states

But it is? They forced Romania to do a re-election because they didn't like the candidate. And they still try to force Chat Control, try to bypass the unanimity rule and the EU commission gives itself more powers every day with authoritian laws like the DSA. As a European, I don't get the USA's EU-fetish. It's not better here than in the US.

EU did not force Romania. Romania itself annulled them because Russian intervention happened.

Aurornis 5d ago

> The US should it not turn this around in the midterms is finished as a liberal democracy.

I wish there was an easy way for me to bet against the imminent fall of the United States as predicted by so many internet commenters. I don’t like what the current administration is doing, either, but I would readily bet against all of these “the end is just around the corner” or “the empire is dying” takes in a heartbeat.

I didn't say the US is finished, I said it was finished as a liberal democracy.

It's already slid in to 'electoral democracy' instead of 'liberal democracy' the difference between the two is how 'rule of law' is prioritised and the balance between checks and balances between institutions is enforced.

https://www.v-dem.net/documents/60/V-dem-dr__2025_lowres.pdf

colin_jack 5d ago

Not quibbling but to be fair that report shows problems in Europe too, not the same speed of change, and its a different situation, but if you care about democracy its not great.

AFAIK there's no murdering of citizens going on in any EU member country by the same countries government at the moment.

Trends are various. You had Poland remove rightwing goverment 2 years ago (yes and elect righwing president few months ago). Romania electing a European centric president.

We can go on. EU is not a single country, not a single community of people.

copper4eva 5d ago

His comment did not even mention the US. Only critiquing the authoritarianism going on in the EU. One of the issues with modern politics is everyone wants to deflect.

nozzlegear 5d ago

> the complete 180 in direction the US is taking and descending in to authoritarianism while moving against the world order

The EU is just one AfD win away from doing the same thing. It's not immune to this issue either, you have the same problem happening right under your noses.

epolanski 5d ago

Not really.

Most European countries have parliamentary democracies.

It's not a winner-takes-all system ala presidential and semi-presidential republics where effectively individuals:

1. rule without opposition. There's no opposition it's not represented in that branch.

2. rule without even needing support of their own parties. The Italian prime minister or the German chancellor have to fight every day in parliament to have support of their parties and the other parties coalitions.

3. a single individual can claim popular mandate. In parliamentary systems you vote for parties/coalitions, not individuals

There's a reason why this authoritarian trend goes from the Philippines, Nicaragua, to Belarus, to Turkey, to Russia, to most African countries and now US. They are all presidential republics.

The last parliamentary democracy to turn authoritarian has been...Sri Lanka. Almost 50 years ago. Presidential ones? It's basically every year.

Systems with winner-takes-all mechanics do not represent voters, and power is too concentrated.

Parliamentary democracies might be labeled as less efficient, that I can agree, but they have strong antibodies to such people.

See Austria or the Netherlands as examples where strong far right authoritarian-wannabes individuals became prime ministers...and then nothing happened and their governments didn't last.

noobermin 5d ago

Europeans are so blind to how they are essentially on the same path as the US, the US just got there first.

While there is a trend toward the right in many (not all) EU countries, it's a far cry from the shit show on the other side of the Atlantic.

Most European countries have functioning legal and electoral systems, and more than two parties. On top of that, constitutional courts aren't political appointments.

So it would be incredibly hard for a political entity like AfD or RN to gain full and absolute power like the orange has achieved. Even in the worst cases, those parties usually only have ~30% popular support at most, which usually translates to at most ~30-40% of seats in parliament. Which means they cannot even get parliamentary majority, and probably can't get head of state either.

Americans just like to pretend things aren't that bad and they aren't the only ones falling into the abyss.

Lol what does ICE have to do with a local police officer being able to bully a tech worker into providing your private communications?

You are technically correct but seem to be applying common law standards to civil law countries.

Unlike common law judiciary, civil law judiciary in and of itself has investigatory powers and judges don’t just hear arguments but can order their own investigations and are significantly more independent than in common law.

This can cut both ways, yes in theory the judge can accept evidence the prosecution obtained illegally, but the judges can also call the prosecutions bluff and call their own witnesses or order an independent expert to provide their own opinion, even if defense is unable to.

Our company started migrating our tech stack from USA to EU. We are about 90% there with a few small dependencies that could be resolved but we have not yet tackled.

flowerthoughts 5d ago

Could you summarize the easy and hard aspects? Have you had any unexpected benefits or downsides?

https://bunny.net/ seems solid as a Cloudflare and S3 replacement. I'm not affiliated but they deserve more mentions in these threads.

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christophilus 5d ago

Used them in my last project for around 5 years. They were boring in a good way and inexpensive.

I use them too. Highly recommend. Have never had an issue with them.

dinowars 5d ago

> First, I tried mailbox.org, which I can generally recommend without reservation. Unfortunately, you can’t send emails from any address on your own domain without a workaround

I use mailbox for a long time, one account for 2.50EUR/month with multiple custom domains and I can send emails from any address. To send from a different address the process didn't really seem different than other providers.

From Thunderbird mobile on Android I just add a new sender identity. If I need to send from webmail, similarly I just add a new alternative sender. Are these the workarounds you mentioned?

My understanding is that the number of such sender aliases is limited, at most 50 or 250, depending on the plan. There are ways to use a custom domain for sending where you end up using a larger number of localparts fairly quickly, and it would be a hassle to have to manage them, instead of just typing whatever sender you want (or on replies, having the email client automatically use the address from the original email, without having to worry whether it’s still in the set of registered aliases).

akvadrako 5d ago

I use mailbox for the past few years and I think it's the best option out there. But they have one major issue, which is that anyone can impersonate your domain:

https://userforum-en.mailbox.org/topic/anti-spoofing-for-cus...

Anti-spoofing for Custom Domains (SPF, DKIM & DMARC)

Does mailbox.org offer anti-spoofing options for custom domains? I can find no information about this on the help pages. Other privacy-oriented providers,

solstice 5d ago

Oof, what a drag

mentalgear 5d ago

Have been using mailbox.org with a custom domain (including catch-all wildcard) for the last 5 years or so, so it's definitely possible and as far I remember quite straightforward.

subzero06 5d ago

Yea been using mailbox.org for couple months and i can send from any address of my own domain...this is bad article. He probably doesn't know how to.

Can confirm, I use mailbox.org with my own domain and can send from any *@mydomain

darthcloud 5d ago

As a Canadian, I’ve been thinking since last year about migrating to non-US services and applications.

My main goal is simply to avoid giving money or data directly to US corporations. I have no illusions, these non-US services probably still benefit US companies in some ways.

They’re rare, but I’ve consciously decided to stay away from some Canadian alternatives. The main customers of most Canadian tech companies are in the US, and I feel they would happily move there if needed.

I started with this:

Gmail / Drive → Proton Mail / Drive

NameCheap / GoDaddy → Infomaniak

Google Maps → TomTom

Google Chrome → Vivaldi

Google Search → Startpage (Vivaldi default)

GitHub → Codeberg & Codefloe (for private)

I do like Proton Mail. The main thing I hate is how often the app and web versions get out of sync for read and archive states.

I’m really happy with Infomaniak, migrating all my domains was a breeze.

Vivaldi is based on the Chrome codebase, but I really love all the extra customization options. It was a very easy switch.

Startpage took me some time to get used to. It’s not as good as Google, but whatever.

TomTom isn’t great, but it’s not like Maps has been great over the last few years either.

Forgejo is much better than what GitHub has become.

Next, I’m thinking of moving away from Google Photos. I’m considering pCloud for that.

mentalgear 5d ago

For Photos, consider Ente (e2ee).

Instead of Startpage, try DDG (DuckDuckGo) - been using it now for several years instead of Google as I found no difference in search quality.

wccrawford 5d ago

Their whole point was to avoid US companies.

Consider ecosia for search. It's not perfect but is decent for most general searches

commandlinefan 5d ago

> avoid giving money

You're paying for any of these?

Most of those services are paid by terrible people when you use them.

Look at their revenue breakdowns.