understaffed. As noted by the Director of the Asylum Service, in a response of 16 February 2024 (prot. no. 58515) to an intervention by 16 NGOs of the Legal Working Group, 1433 only two employees are in charge of processing all the travel document renewal applications throughout Greece. 1434 According to the National Register of Procedures, the travel document renewal procedure may last up to two months.1435 However, in GCR’s experience, the procedure may last up to six months. Contrary to the above, the beneficiaries of international protection for whom the competent authority is the Headquarters of the Hellenic Police, 1436 have to appear in person before the competent Aliens Directorate both for the initial issuance and the renewal of their travel documents in order to submit their relevant applications. GCR has noticed that, despite the provisions of JMD 10302/2020 for beneficiaries of subsidiary protection, according to which travel documents are valid for three years, the travel documents of beneficiaries of subsidiary protection are renewed for two years. As per information provided by the Headquarters of the Hellenic Police on 28 February 2026, during 2025, a total of 25 new travel documents were issued and 333 were renewed by the Headquarters of the Hellenic Police. By the end of 2025, a total of 1,515 applications for renewal of travel documents were pending before the GAS, and in particular the competent AAU for Beneficiaries of International Protection, a significant majority (70.6%) of which were pending for more than 6 months. 1437 According to an ongoing survey conducted by UNHCR, from 1 January 2025 to 20 November 2025, out of 99 beneficiaries surveyed, 48% had applied for a travel document and had received it, 41% were waiting, while 10% had not yet applied.1438 It must be stressed that travel documents are a prerequisite for opening a bank account in Greece, as banks do not accept ADET as valid identification documents for beneficiaries of international protection who wish to open a bank account. The issue of the link between possession of travel documents and the ability to open a bank account was already highlighted in a survey conducted by UNHCR from July 2022 – June 2023 with 424 beneficiaries of international protection. 43% of those interviewed reported that they had travel documents and only 42% had bank accounts.1439 Possession of a travel document is also needed for access to employment, since the Unified Social Security Fund (Ενιαίος Φορέας Κοινωνικής Ασφάλισης, EFKA) does not accept ADET as a valid documentation.1440 Furthermore, travel documents are in practice a prerequisite to access the platform of the Ministry of Finance (AADE). Specifically, ‘the AFM provides access to the online system TAXISnet. […] After an AFM has been issued, the applicant receives an account and TAXISnet codes, which are needed in order to access the systems of the tax authority and other public administrative services online […] Access codes (TAXISnet codes) are requested online through the AADE platform. […] The platform accepts only 1433 Letter of Director of the Asylum Service, Renewal of identity documents of beneficiaries of international protection, prot. no. 58515/16.02.2024. 1434 Ibid. 1435 National Register of Procedures, Travel Documents Renewal for Beneficiaries of International Protection available in Greek at: https://tinyurl.com/28w6h893. 1436 Headquarters of the Hellenic Police is the competent authority for beneficiaries of international protection who have applied for international protection before the Asylum Service started its operation. 1437 RSA, Recognised refugee statistics in Greece in 2025, March 2026, available at: https://tinyurl.com/435psr2v, p.4. 1438 UNHCR, Greece Inter-Agency Protection Monitoring of refugees in Greece, Key Findings, 01 February 2022 – 20 November 2025, available at: https://tinyurl.com/k9vtxdwy. 1439 UNHCR, Key Findings: July 2022 – June 2023, Protection Monitoring of Refugees in Greece, August 2023, available at: https://bit.ly/4dgyE2l. 1440 RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socioeconomic rights, March 2024, available at: https://bit.ly/3Vy9DYJ, p. 17. 280