issue AFM to asylum seekers upon the lodging of their claims. People have to refer to
the territorially competent RAO to complete the process.
Processing of asylum clams in the RIC
Beyond uniform registration, the processing of asylum applications deemed manifestly
unfounded or relating to single adults originating from “safe countries of origin” 45 takes
place in the RIC of Malakasa and Diavata, according to informal information from the
authorities. However, no information is made publicly available on the categories of
applications processed during the “restriction of liberty” imposed on applicants within
the RIC.46 Due to this, applicants do not receive full and timely information “upon the
making of the application… on the procedure followed”, as required by law.47
Moreover, reports indicate that the above procedure entails remote interviews as a
rule and that border procedure provisions are – erroneously – applied, due to which
the Asylum Service grants a shorter ten-day deadline for appeal against negative
decisions.48
Onward transfer to reception facilities
After uniform registration has been completed at the RIC of Malakasa, the RIS refers
applicants who declare that they need reception conditions to a reception facility,49
since camps are now the only form of accommodation offered by Greece.50 Asylum
seekers may placed in any camp on the mainland, regardless of where they resided
prior to the reception and identification procedure. For example, after the application
was lodged, Raheel* was placed in the Alexandria camp even though she was staying
in the RIC of Malakasa until her registration, Naiem* and Nooria* were placed in the
Schisto camp where they were residing prior to their registration, Zarifa* was moved to
the Thiva camp, Frishta* to the Filippiada camp and Rohullah* to the Koutsochero
camp. Shabnam* was placed in the RIC of Malakasa.
Conclusions and recommendations
Drawing on the above analysis, Refugee Support Aegean (RSA) makes the following
observations:
1. Greece contravenes international, EU and domestic law by setting constraints
on the “making” of asylum applications, i.e. the expression of intention to lodge
an asylum claim subject to no “administrative formality”, upon which
“applicant for international protection” status is acquired. The request for a
registration appointment via the Ministry of Migration and Asylum, the sole and
dedicated channel for asylum seekers’ access to the Responsible Registration
45
46
47
48
49
50
JMD 708368/2022, Gov. Gazette Β΄ 6012/25.11.2022.
Pursuant to Article 40(c) Asylum Code.
Article 74(1) Asylum Code.
Articles 95(1) and 97(1)(c) Asylum Code. On the scope of the border procedure, RSA et
al., The state of the border procedure on the Greek islands, September 2022, 13-15.
Article 43(d) Asylum Code.
RSA, ‘On the termination of the ESTIA II housing programme for asylum applicants’, 22
December 2022, available at: https://bit.ly/3luaL12.
13
RSA REPORT │ 2023
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