in response to the intervention of 16 NGOs of the national Legal Aid Working Group, 1272 only 8 employees were then in charge of processing the total volume of renewal applications (including decisions on renewal) throughout Greece.1273 During the renewal procedure, the Asylum Service conducts criminal record checks, which may lead to the withdrawal of protection status, as well as an assessment of whether the grounds on which international protection was granted continue to apply. Pending the renewal process, beneficiaries are provided with an attestation of application status (βεβαίωση κατάστασης αιτήματος)1274 which is valid for three or six months, depending on the RAO or AAU that is competent for issuing it. This attestation provides beneficiaries with access to less rights (e.g. no access to the labour market, social welfare or to public healthcare, with the exception of emergencies) than the attestation of Article 11(10) L. 5038/20231275 issued for migrants. In fact, beneficiaries of international protection holding these attestations are only protected from detention and have no access to their rights pending the renewal of their residence permit. As far as GCR is aware, a main reason for this is that public services, such as the Public Employment Service (Δημόσια Υπηρεσία Απασχόλησης/ΔΥΠΑ, formerly OAED), are reluctant to accept these attestations, since they lack security features and a photograph of the beneficiary. Given a photograph of each beneficiary is available in their file, which is held by the Asylum Service, this issue could be at least partially and easily resolved by obtaining the beneficiary’s photograph, either from the attached file of the electronically submitted application for renewal, or from the administrative file kept by the Asylum Service, which includes their "facial image". Such a procedure has not been implemented to date. 1276 Furthermore, a day after the residence permit expires, beneficiaries’ Social Security Number (AMKA) is deactivated.1277 This creates an additional bureaucratic layer and delays, as, in order to re-activate it, beneficiaries need to submit the attestation of application status, along with other documents required under JMD Φ80320/109864/14.12.2023.1278 Yet the attestation can only be issued after the application for renewal has been first uploaded by the competent Asylum Unit for Beneficiaries of International Protection to the electronic system of “ALKYONI” (ΑΛΚΥΟΝΗ). In GCR’s experience, this can take even up to a month from the time beneficiaries have submitted their application for renewal. That being said GCR is aware that in 2025, in certain cases, the applications were uploaded within a maximum of 15 days. This is in spite of Article 12 of the Code of Administrative Procedure (L. 2690/1999), which requires public authorities to record any document received on the same day. The Ombudsperson has flagged this obligation to the Asylum Service in the specific context of ADET renewal applications.1279 In response, the administration has provided the Ombudsperson with 1272 1273 1274 1275 1276 1277 1278 1279 Intervention by 16 civil society organizations of the national Legal Working Group to the Minister and Vice Minister of the Ministry of Migration and Asylum, Renewal of identification documents of beneficiaries of international protection, prot. no. β/117/15.02.2024. Said intervention raised the following issues: (a) Long delays in the processing of applications for renewal of ADETs and travel documents by the Asylum Service, (b) Non-acceptance of the Asylum Service's "Certificates of beneficiaries of international protection", (c) Obstacles in the communication of beneficiaries and legal representatives with the Asylum Unit of International Protection Beneficiaries, (d) Ineffective means and procedures for the service of the issued ADETs and travel documents by the Asylum Service. Letter of Director of the Asylum Service, Renewal of identity documents of beneficiaries of international protection, prot. no. 58515/16.02.2024. Article 13 JMD 513542/2022, Gov. Gazette Β ́ 4763/12.09.2022. L. 5038/2023 “Immigration Code”, Gazette 81/A/01-04-2023. On 16 February 2024, in response to the aforementioned intervention of the Legal Aid Working Group, the Director of the Asylum Service noted that the legislation would be amended so that renewal applications would be processed electronically, through a platform, from where certificates of pending renewal would also be issued. This legal framework would also define specific requirements for the certificate, that would make it possible to verify the validity of the data and the authenticity of the document, in line with the standards of the Immigration Code. Such certificates would also include provisions for their general acceptance by third parties. Yet the adoption of relevant legislation is pending. Article 7 JMD Φ80320/109864/14.12.2023, Gov. Gazette B 7280/22.12.2023. Article 8 in conjunction with Articles 5 and 6 of JMD Φ80320/109864/14.12.2023, Gov. Gazette B 7280/22.12.2023. 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. 9. 255