According to Article 98 Asylum Code, the appeal, inter alia, has to be submitted in writing and mention the “specific grounds” on which the applicant relies to challenge the first instance decision. If these conditions are not fulfilled, the appeal is rejected as inadmissible without an examination on the merits. This provision has been largely criticised as it severely restricts access to the appeal procedure in practice, and appears to contradict EU law.420 As noted by UNHCR at the time of the provision’s introduction in law in 2019 (under Article 93 IPA), “[i]n some circumstances, it would be so difficult to appeal against a rejection that the right to an effective remedy enshrined in international and EU law, would be seriously compromised”.421 In practice, the requirements set by the Asylum Code (and previously by the IPA) can only be fulfilled when a lawyer assists the applicant. Yet considering the gaps in the provision of free legal aid, this remains a challenge. Out of the total 12,039 appeals against first instance negative decisions submitted in 2024,422 legal aid was provided in less than two out of three cases (total of 7,902 423 cases or roughly 65.63% of cases). 424 Since it is unlikely that a third of appellants (4,137 or 34.36%) had either sufficient funds to secure a private lawyer and/or received free legal aid by NGOs, as in previous years, 425 this discrepancy highlights the ongoing challenges that applicants face in accessing and securing state funded free legal aid and in turn in accessing effective remedies. During 2025, a total of 12,552 appeals against first instance negative decisions were submitted.426 A total of 48 appeals were rejected as inadmissible on formal grounds («τυπικοί λόγοι») during 2025.427 No information on legal aid statistics is available for 2025. Nonetheless, since the number of appeals is higher than in 2024, and the capacity of the legal aid registry remains the same, it is safe to conclude that the applicants faced the same challenges in assessing free legal aid. Suspensive effect The Asylum Code provides for the suspensive effect of appeals before the Appeals Authority. It also introduces a number of exceptions to this rule. In particular, those concerning applications rejected in the accelerated procedure or dismissed as inadmissible under certain grounds. In such cases, the appellant may submit an application before the Appeals Committees, requesting their stay in the country until the second-instance appeal decision is issued. Suspensive effect covers the period “during the time limit provided for an appeal and until the notification of the decision on the appeal”. 428 More precisely, according to Article 110 Asylum Code, 429 the appeal does not have an automatic suspensive effect in case of an appeal against a first instance decision rejecting the application as inadmissible: 420 421 422 423 424 425 426 427 428 429 Namely Article 46 of the recast Asylum Procedures Directive and Article 47 of the EU Charter of Fundamental rights. UNHCR, UNHCR urges Greece to strengthen safeguards in draft asylum law, 24 October 2019, available here. MoMA, Statistics, Consolidated Reports - Overview: December 2024 – International Protection | Appendix A, available in Greek https://tinyurl.com/26ynfarp table 9a. It is also worth noting that according to the data provided by the Ministry of Migration and Asylum, in response to Parliamentary Question no 3383/838/13.02.2025, 7,491 persons applied for legal aid in 2024, while 7,902 persons received it. As per information disclosed by the Minister of Migration and Asylum in reply to parliamentary question no. 3383/838/13.02.2025 on 7 March 2025. The reply is available in Greek at: https://tinyurl.com/2xwpkare. For instance, AIDA report on Greece: 2021 update, May 2022, available here, 20 and AIDA report on Greece: 2022 update, June 2023, available here, 71. MoMA, Statistics, Consolidated Reports - Overview: December 2025 – International Protection | Appendix A, available in Greek https://tinyurl.com/26ynfarp , table 9a. MoMA, Statistics: Consolidated Reports – Overview, December 2025 - International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 8b. Article 110(1) Asylum Code. Article 104 L. 4636/2019 as amended by Article 20 L. 4825/2021 and Article 110 Asylum Code. 91