The same applies to beneficiaries of subsidiary protection or family members of beneficiaries of
international protection, if they are unable to obtain a national passport, unless compelling reasons of
national security or public order exist. 1421 In practice, beneficiaries of subsidiary protection must submit to
the Greek authorities a verification from the diplomatic authorities of their country of origin, certifying their
inability to obtain a national passport. This prerequisite is extremely onerous, as beneficiaries of subsidiary
protection may also fear persecution or ill-treatment from their country of origin. Furthermore, the issuance
of this verification is at the discretion of the diplomatic authorities of their country of origin and depends
on the policy of each country. The travel documents issued for beneficiaries of subsidiary protection are
valid for 3 years and can be renewed.1422
JMD 10302/2020 provides that the Passport Directorates of the Hellenic Police are the only competent
authority for the issuance of travel documents. 1423 In practice, after their recognition, beneficiaries of
international protection must scan all the required documents (including the electronic administrative fee)
and send them by email to the competent Alien’s Directorate in order to book an appointment for the
submission of their applications in person. Travel documents are issued by the Passport Offices of the
Hellenic Police. Beneficiaries of international protection are required to book an appointment, similar to
the one for their residence permit (ADET). In case of travel documents, however, the payment of a fee is
a prerequisite to obtaining such an appointment. 1424 After the travel document is issued, they must
regularly check the website of the Asylum Service for their scheduled appointment. 1425 If they miss that
appointment, they must book another one through the electronic platform of the Ministry of Migration and
Asylum, which may be scheduled months after the missed one. Travel documents may only be collected
at the RAOs of Attica, Thessaloniki and Crete. This means that beneficiaries of international protection
on the islands have to travel either to Athens or to Thessaloniki to collect their document. 1426
The same Ministerial Decision regulates the issuance of travel documents for children accompanied by
one of their parents who de facto exercises on their own the sole custody of the child, but does not possess
documents establishing the sole custody of the child (e.g., divorce, court order on sole custody, death
certificate). More precisely travel documents for children can be issued upon submission to the competent
Passport Office of a declaration on oath before a Lawyer or a Notary 1427 when the following conditions
are met:
❖ the child is granted refugee status and is present in Greece with one of their parents;
❖ this parent is also exercising the sole custody due to facts or legal acts that have occurred in the
country of origin (e.g., death of a spouse. divorce), and
❖ this parent does not possess documents proving that they are exclusively exercising the sole
custody.
However, Article 1(6) of JMD 10302/2020 does not apply to cases where the parent is exercising sole
custody due to facts or legal acts that have occurred in a country other than the country of their origin. In
this case, if no supporting documents can be provided, travel documents for children can be granted only
by a court order, pursuant to which the sole custody is assigned to the single parent. 1428 The waiting
period for the initial issuance of travel documents is not as lengthy as it used to be, as far as GCR is
aware.
As regards the renewal of travel documents, beneficiaries of international protection have to follow a fivestep procedure. In particular, the beneficiary has to:
a. submit a renewal application and a photo via email to the Asylum Service,
1421
1422
1423
1424
1425
1426
1427
1428
Article 24(3) Asylum Code.
Article 6(2) JMD 10302/2020.
Article 3 JMD 10302.
RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socioeconomic rights, March 2024, available at: https://bit.ly/3xsmCTB, p. 18.
MoMA, Travel documents, available at: https://bit.ly/2Pd4kQe.
RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece: Access to documents and socioeconomic rights, March 2022, available at: https://bit.ly/3lRUB1C para. 33.
Article 1(5) JMD 10302/2020 (The District Courts in Greece do no longer exist), Article 421 Civil Procedure
Code as in force.
Articles 1(6) and 1(7) JMD 10302/2020.
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