Macedonia. The official statistical data for 2024 do not break down the cases according to nationality
(Syrian, Afghan, Somali, Pakistani or Bangladeshi), nor has such data been provided following GCR’s
yearly requests. According to the relevant statistics for 2025, only 66 “inadmissible/safe country of origin”
decisions were issued by the Appeals Committee, 11 inadmissibility decisions under the border procedure
concerning Albania as a 'safe third country', and 27 inadmissibility decisions under the border procedure
concerning North Macedonia as a 'safe third country.858 No additional data are available.
Decisions of the Appeals Committees rejecting cases as inadmissible follow the line of reasoning of the
Asylum Service to a great extent. Appeals Committees have continued to refrain from taking into
consideration up-to-date and reliable sources of information concerning risks of inhuman or degrading
treatment and refoulement facing individuals in Türkiye. Appeals Committees have also held that the
designation of a third country as safe may be maintained, even in cases where the applicant invoked
reports by international organisations reaching the opposite conclusion. 859 Greek authorities come to the
conclusion that applicants do not face a risk of refoulement in Türkiye on the ground that they had not
already faced such treatment in the country prior to their arrival in Greece. 860 Only in a few exceptions
have the Independent Appeals Committees (IACs) cited Türkiye’s practice of coercion of refugees into
signing “voluntary return” forms.861 Furthermore, none of the Asylum Service and IAC decisions seen in
2024 or early 2025 refer to authoritative evidence on the current state and deficiencies of the Turkish
asylum system, including a “20% rule” on registration of international and temporary protection claims in
all provinces with a significant population of non-nationals, and removal of tens of thousands to countries
such as Afghanistan and Syria. Almost none refer to the country’s “20% rule” on access to asylum
procedures.862
To GCR’s knowledge there have been certain appeals of Syrians which have been considered as
admissible at second instance.863
2.2.
Connection criteria
Article 91(1)(f) Asylum Code requires there to be a connection between the applicant and the “safe third
country”, which would make return thereto reasonable. Whereas no further guidance was laid down in
previous legislation864 as to the connections considered “reasonable” between an applicant and a third
858
859
860
861
862
863
864
MoMA, Statistics, Consolidated Reports - Overview: December 2025- International Protection | Appendix A,
available at: https://tinyurl.com/26ynfarp table 8a 8b
2nd IAC, 171515/2023, 23 March 2023, p. 7; 8th IAC, 583703/2022, 5 October 2022, p. 12; 511455/2022, 5
September 2022, p. 19; 237130/2022, 29 April 2022, p. 16; 161054/2022, 21 March 2022, p. 13; 142176/2022,
11 March 2022, para 9; 458313/2021, 15 December 2021, para 9; 11th IAC, 71895/2022, 8 February 2022,
para 13; 67923/2022, 7 February 2022, para 9; 384227/2021, 15 November 2021, para 9; 2075/2021, 26
February 2021, para 11; 2727/2020, 9 April 2020, para 10; 13th IAC, IP/113682/2023, 13 September 2023,
para 11; 22148/2023, 13 January 2023, para 8; 734754/2022, 7 December 2022, para 9; 14th IAC,
IP/335367/2023, 6 December 2023, p. 18; 250567/2023, 3 May 2023, p. 24; 211179/2023, 11 April 2023, p.
24; 16th IAC, 85916/2023, 10 February 2023, para IV.4; 394674/2022, 7 July 2022, p. 7; 21st IAC,
710801/2022, 28 November 2022, pp. 9-10; 690292/2022, 18 November 2022, p. 8; 467020/2021, 20
December 2021, p. 10, as cited in ProAsyl and RSA, The concept of “Safe third country”. Legal standards and
Implementation in the Greek Asylum System, February 2024, available at: https://bit.ly/44fR5jV, p. 10, note
29.
For example, 3rd IAC, 47496/2022, 28 January 2022, para 15; 4th IAC, 204504/2023, 7 April 2023, pp. 1819; 79499/2023, 8 February 2023, para III.2; 6th IAC, IP312088/2023, 28 November 2023, para IV.5;
IP/291367/2023, 21 November 2023, para IV.5; 11th IAC, IP/578/2023, 28 June 2023, pp. 24-25; 12th IAC,
168365/2023, 7 April 2023, p. 15; 14th IAC, IP/335367/2023, 6 December 2023, p. 21; 250567/2023, 3 May
2023, p. 26; 211179/2023, 11 April 2023, pp. 25-26.
10th IAC, 22083/2020, 28 April 2021, para 2; 12540/2020, para 4; 17th IAC, 292768/2023, 8 June 2023, para
3; 21st IAC, 398486/2021, 19 November 2021, p. 20, as cited in ProAsyl and RSA, “The concept of “Safe third
country”. Legal standards and Implementation in the Greek Asylum System, February 2024, available at:
https://bit.ly/44fR5jV, p. 12, note 43.
Exceptions include 4th IAC, 204504/2023, 7 April 2023, pp. 14 and 17; 12th IAC, 168365/2023, 22 March
2023, pp. 11 and 14; 15th IAC, IP/20208/2024, 10 January 2024, para 16, as cited in ProAsyl and RSA, “The
concept of “Safe third country”. Legal standards and Implementation in the Greek Asylum System, February
2024, available at: https://bit.ly/44fR5jV, p. 10, note 29.
GCR, HIAS, RSA, Greek Asylum Case Law Report Issue 1/2024, available here; GCR, HIAS, RSA, Greek
Asylum Case Law Report Issue 2/2024, available here.
Article 56(1)(f) L 4375/2016.
184