Until the issuance of their residence permits, beneficiaries keep their asylum applicant card and are considered as asylum applicants by ERGANI (ΕΡΓΑΝΗ) –the Information System of the Ministry of Employment.1264 In practice, this means that pending the receipt of their ADET, beneficiaries do not enjoy full access to the labour market, as per their rights, but instead face the same limited access/restrictions faced by applicants of international protection (i.e. no possibility to engage in independent economic activity, and, if status recognition takes place in less than two months from the lodging of their asylum application, no access to the labour market until the two months have lapsed). 1265 After delivery of the residence permit (A.Δ.E.T), the Asylum Service notifies the Electronic Governance of Social Security S.A. (ΗΔΙΚΑ Α.Ε.) to deactivate the Provisional Foreigner’s Insurance and Health Care Number for asylum applicants (ΠΑΑΥΠΑ). Along with the delivery of the residence permit, the Asylum Service is obliged to inform beneficiaries of international protection that they are henceforth eligible to acquire a social security number (AMKA) and that they must take the legally required steps to issue it within one (1) month.1266 In practice, due to delays linked with the electronic system of ΗΔΙΚΑ, beneficiaries have no access to health care for many months until their AMKA number is activated. Renewals An application for renewal needs to be submitted no later than 30 calendar days before the expiry of the residence permit. The mere delay in an application for renewal, without any justification/reason, cannot lead to its rejection.1267 However, in case of delayed submission without due reasons, a EUR 100 fine is foreseen.1268 The authority responsible for imposing the fine is determined by Joint Ministerial Decision of the Ministers of Migration and Asylum, and of Finance. 1269 In practice, this fine has never been imposed. Since 2017, the application for renewal, together with a digital photo of the beneficiary, is submitted via email to the Asylum Service (Asylum Unit of International Protection Beneficiaries -Αυτοτελές Κλιμάκιο Ασύλου Δικαιούχων Διεθνούς Προστασίας) and the latter’s decision is notified to the applicant also via email. Bearing in mind that legal aid is not provided at this stage, technologically illiterate beneficiaries face obvious obstacles to apply for the renewal of their permit. As in previous years, long waiting periods for the renewal of ADETs have continued being an issue of concern in 2025 as well, with average waiting times being officially reported at 4 months.1270 However, based GCR’s caseload experience, 4 months tends to be the minimum waiting period for an ADET renewal, with delays of even a year still reported in 2025.1271 To GCR’s knowledge, these delays are due to the high number of applications and the severe understaffing of the competent Asylum Unit of International Protection Beneficiaries (Αυτοτελές Κλιμάκιο Ασύλου Δικαιούχων Διεθνούς Προστασίας). Indicatively, as noted in a 16 February 2024 (prot. no. 58515) letter of the Director of the Asylum Service 1264 1265 1266 1267 1268 1269 1270 1271 See website of the Ministry of Employment: https://bit.ly/3KZj7oE. Article 192 L. 5078/2023 (Gov. Gazette A 211/20.12.2023), amending Article 57(1) Asylum Code. Articles 10 & 11, JMD Φ80320/109864/14.12.2023, Gov. Gazette B 7280/22.12.2023. Article 23(1) Asylum Code, JMD 513551/2022, Gov. Gazette Β ́ 4763/12.09.2022 Article 23(1)(7) Asylum Code. As inter alia noted in a 2023 Circular of the MoMA: “Delayed application for renewal of ADET without reason” should be interpreted as follows: “the mere submission of any reason for negligence on the part of the beneficiary in submitting the application in time shall not suffice. Reasons shall be given which in fact justify exceeding the deadline set by law on the basis of objective criteria or events, without mandatory written evidence. The reasons invoked by the applicant shall be accepted where they are in line with the conduct of the ordinary reasonable person”. Ministry of Migration and Asylum, Circular 69244/2023 – Εγκύκλιες Οδηγίες σχετικά με την εφαρμογή της με Αριθμ. 513551/05.09.2022 (Β ́ 4763) Κοινής Απόφασης των Υπουργών Οικονομικών και Μετανάστευσης και Ασύλου «Καθορισμός του αρμόδιου οργάνου επιβολής και της διαδικασίας βεβαίωσης του προστίμου του έβδομου εδαφίου της παρ. 1 του άρθρου 23 του ν. 4939/2022 (Α’ 111)», 1 February 2023, available at: https://tinyurl.com/mtbt72ux, p.4. Also see 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. 8. See also RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socio-economic rights, March 2023, available at: https://bit.ly/45y1CY1, pp. 6-7. Article 17 L. 4825/2021. JMD 513551/05.09.2022, Gov. Gazette Β ́ 4763/12.09.2022. Hellenic Republic, National Registry of Administrative Procedures: Renewal of Uniform Format Residence Permits (ADET), in Greek: https://tinyurl.com/yhkrzbx7 [last updated on 9 April 2025]. Also see RSA, Recognised Refugees 2025, March 2025, available at: https://tinyurl.com/3emyk5w3, p.14. 254