Introduction Since September 2022, Greece applies screening (hereafter “reception and identification”) procedures to irregularly arriving or staying third-country nationals and stateless persons on the mainland, in addition to existing procedures at the Evros land border and on the islands,1 under the responsibility of the Reception and Identification Service (RIS) of the Ministry of Migration and Asylum. According to a circular of said Ministry, as a rule, persons who are present on the mainland and have not previously undergone reception and identification procedures shall lodge their asylum applications at the Reception and Identification Centres (RIC) of Malakasa and Diavata, near Athens and Thessaloniki respectively. 2 The two facilities were reestablished as RIC with a November 2022 amendment to the organisational structure of the Ministry.3 The Ministry of Migration and Asylum had already barred direct access to the Asylum Service for those who had not previously undergone reception and identification procedures under a November 2021 circular.4 In July 2022, it launched a special online platform5 for the booking of appointments for reception and identification procedures and lodging of asylum claims at the RIC of Malakasa and Diavata as “Responsible Registration Authorities”.6 The launch of this “uniform registration” procedure in mainland Greece is a significant development for the country’s asylum system, marred for over a decade by structural problems regarding access to the procedure.7 It also presents important legal issues at European Union (EU) level in view of upcoming negotiations between the European Parliament and the Council on the proposal for a Screening Regulation, tabled by the European Commission on 23 September 2020 as part of the New Pact on Migration and Asylum.8 The Screening proposal is largely modelled on the Greek reception and 1 2 3 4 5 6 7 8 Lesvos, Chios, Samos, Leros and Kos. See European Council, EU-Turkey Statement, 18 March 2016, available at: https://bit.ly/2S5qaAg. Ministry of Migration and Asylum, Circular 504912/2022, 31 August 2022. The Circular is accompanied by RIS Director Decision “Establishment of two (2) Registration and Transfer Coordination Mobile Units”, 504264/2022, 31 August 2022. Articles 34(h)-(i) PD 106/2020, Gov. Gazette A’ 255/23.12.2020, inserted by Article 12 PD 77/2022. Note that the new RIC of Malakasa encompasses two formerly operating reception facilities: “old” and “new” Malakasa. See e.g. RSA, ‘New Malakasa: Inhuman subsistence, nine months on’, 17 December 2020, available at: https://bit.ly/3HTTiXp. Ministry of Migration and Asylum, Circular 411695/2021, 24 November 2021. Ministry of Migration and Asylum, Registration appointment application, available at: https://bit.ly/3HY6bzQ. Articles 1(q) and 69(7) Asylum Code, L 4939/2022, Gov. Gazette A’ 111/10.06.2022. ECtHR, M.S.S. v. Belgium and Greece, App No 30696/09, 21 January 2011; Council of Europe Committee of Ministers, 1383rd meeting (29 September - 1 October 2020) (DH) H46-7 M.S.S. and Rahimi groups v. Greece (Application No. 30696/09), CM/Del/Dec(2020)1383/H46-7, 1 October 2020, available at: https://bit.ly/3kQ2m7y. Note that the position expressed by the Greek government to the Council of Europe Committee of Ministers in 2021, per which “Those who have expressed their intention to apply for asylum can submit their registration themselves electronically”, does not reflect the current process: Greek Government, The Communication concerning the execution of the M.S.S. v. Greece (30696/09) and RAHIMI v. Greece (8687/08) group of cases judgments rd in response to the decision of the CM at its 1383 meeting, DH-DD(2021)363, 16 March 2021, para 9, available at: https://bit.ly/3R5vG6a. European Commission, Proposal for a [Screening Regulation], COM(2020)612, 23 September 2020. See also Council of the European Union, Proposal for a [Screening 2 RSA REPORT │ 2023

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