In practice, on the mainland, first instance decisions are mainly served to applicants by e-mail, through
their legal representatives or more seldom by registered mail. In cases of electronic notification of first
instance decisions, provision of legal aid for the appeals procedure can be requested either in person at
the competent RAO or through the electronic platform of the Ministry for Migration and Asylum. 389 If the
latter is the only option (e.g., because the applicant lives far from the competent RAO), it significantly
hinders the ability to appeal for those not familiar with the use of electronic applications or who do not
have access to the required equipment/internet. Moreover, in practice, the notification of first instance
decisions is also carried out by the Head of the RICs on the islands and in Evros and the Head of Preremoval detention facilities in Athens (Amygdaleza and Tavros). In both cases, the inability of the
applicants to understand the content of the communicated documents and the procedure they have to
follow has been observed.
1.4.
Appeal
Indicators: Regular Procedure: Appeal
1. Does the law provide for an appeal against the first instance decision in the regular procedure?
Yes
No
❖ If yes, is it
Judicial
Administrative
❖ If yes, is it automatically suspensive
Yes
Some grounds
No
2. Average processing time for the appeal body to make a decision: Reported at 90 days for the
mainland, albeit without specification of the type of procedure concerned and based on data
covering the period between 1 December 2019 to 31 December 2025.390
1.4.1. Administrative review
Since the entry into force of the IPA on 1 January 2020, the Independent Appeals Committees are the
sole administrative bodies competent for the examination of appeals lodged against first instance asylum
decisions.
Establishment and Composition of the Independent Appeals Committees of the Appeals Authority
The legal basis for the establishment of the Appeals Authority was amended several times in recent years
and has been further amended by the IPA.391 More precisely, following an amendment in 2016, the
composition of the Appeals Authorities consisted of two active Administrative Judges in the new threemember Appeals Committees (Ανεξάρτητες Αρχές Προσφυγών) and a third member, holding a university
degree in Law, Political or Social Sciences or Humanities with specialisation and experience in the fields
of international protection, human rights or international or administrative law. 392 According to the
amendment introduced by the IPA, the three-member Appeals Committees are composed by three active
Administrative Judges of First Instance Administrative Courts and Administrative Courts of Appeal.
Moreover, a single member/Judge Committee has been introduced.393
389
390
391
392
393
MoMA, Asylum Services, available here.
MoMA, Statistics: Consolidated Reports – Overview, December 2025 - International Protection | Appendix A,
available at: https://migration.gov.gr/statistika/, Table 10b.
More precisely, it was amended twice in 2016 by L 4375/2016 in April 2016 and L 4399/2016 in June 2016, in
2017 by L 4461/2017 and in 2018 by L 4540/2018; See AIDA, Country Report: Greece, 2019 update, available
here.
Article 5 L. 4375/2016 as amended; the third member is appointed by UNHCR or the National Commissioner
for Human Rights if UNHCR is unable to appoint one. If both are unable, the (now) Minister for Migration Policy
appoints one.
Article 116(2) and (7) IPA.
87