National Commission, among others, is emphasizing once again the "watchdog" role of the media and the fact that their presence is a guarantee for ensuring the accountability of authorities. Additionally, journalists covering refugee issues often face abusive lawsuits (SLAPPs) in the course of their profession, and they are frequently subjected to verbal attacks or hate speech from official state entities or private individuals, with the tolerance of state authorities. Finally, the case of a journalist who was placed under surveillance was mentioned by the National Intelligence Service, due to what is stated, as a result of his journalistic involvement with refugee issues”. The GNCHR, in its statement which was also communicated for information to the Prosecutor's Office of the Supreme Court, urgently calls on the State: ❖ to show zero tolerance for phenomena of harassment, attacks, hate speech, and any other targeting of human rights defenders by official state authorities, adopting a coherent policy to prevent them ❖ Ensure a favourable environment (enabling environment) through the legal framework for the functioning of civil society organisations and other human rights defenders, taking due account of the repeated recommendations of international and European bodies. ❖ Refrain from prosecuting organisations or other categories of human rights defenders for providing humanitarian aid to third-country nationals or for exercising their profession (e.g., lawyers, journalists). For those already facing criminal proceedings, ensure their rights and a swift trial in accordance with the guarantees of Article 6 of the ECHR. Specifically, for lawyers, harmonise their treatment by the relevant state authorities in accordance with the recommendations of the Athens Bar Association. It is noted that the abuse of criminal proceedings constitutes an impermissible measure for "limiting" the activities of civil society organisations. State sanctions of a criminal or civil nature, which have a punitive character and aim to discourage individuals from participating in associations (freedom of association), constitute reprisals and are prohibited. ❖ Ensure the unhindered exercise of journalistic duties and take protective and compensatory measures for victims of "strategic lawsuits against public participation" (SLAPPs), in the context of the relevant European Commission Recommendation. Public officials must refrain from initiating such lawsuits. During 2025, the GNCHR, jointly with the Office of the United Nations High Commissioner for Refugees (UNHCR), expressed their “serious concern about the escalation of negative rhetoric and the increasingly hostile climate developing against refugees, migrants and the civil society organisations that support them”. They further highlighted the particular concern raised by “public statements, initiatives or informal leaks that stigmatise civil society actors or propose the imposition of punitive measures against organisations that may express different views or seek judicial protection on behalf of those they represent”.194 A draft law of the Ministry of Migration and Asylum on the promotion of policies on legal migration, which was released for public consultation on 30 December 2025 - submitted to Parliament on 23 January 2026 - includes a series of provisions 195 hampering the operation of civil society organisations and pave the way for the criminalisation of humanitarian action. 196 According to the Draft Articles 15 and 16 of the draft law introduce, for the first time, the status of membership in a civil society organization (NGO) registered with the Ministry of Migration and Asylum is introduced as an aggravating circumstance for a range of offenses related to the broad and vague concept of “aiding and abetting” and, at the same time, offenses that under the current legal framework were classified as misdemeanors are being reclassified as felonies and punished with multi-year prison sentences. Among other things, Article 15 stipulates that mere membership in a NGO registered in the 194 195 196 The UN High Commissioner for Refugees and the GNCHR express concern about rhetoric against civil society, 28 August 2025, https://www.nchr.gr/ta-nea-mas/2074-i-ypati-armosteia-tou-oie-gia-tous-prosfygeskai-i-ethniki-epitropi-gia-ta-dikaiomata-tou-anthropou-ekfrazoun-tin-anisyxia-tous-gia-ti-ritoriki-se-varos-tiskoinonias-ton-politon.html RSA, Draft Law Attacking Civil Society in Greece RSA comments on the “promotion of legal migration policies” bill” https://rsaegean.org/en/draft-law-attacking-civil-society-in-greece/ GNCHR, Statement on the provisions of the draft law targeting civil society organisations https://www.nchr.gr/en/news/2181-statement-on-the-provisions-of-the-draft-law-targeting-civil-societyorganisations.html 57