Categories exempted from the online platform
Ministry of Migration and Asylum Circular 504912/2022 only exempts unaccompanied
children and persons in criminal or administrative detention from the uniform
registration procedure at the RIC of Malakasa and Diavata. Asylum claims made by
these categories of people continue to be lodged at the Asylum Service.25
The wording of the circular implies that all other asylum seekers are to be registered in
the two RIC after booking an appointment via the online platform. In practice,
however, the Greek authorities seem to exempt certain categories of people from the
requirement of an online appointment via the platform prior to their entry into the RIC,
though no information or criteria are publicly available thereon.
Practice to date suggests that categories exempted from the platform include large
groups transferred by the authorities to the RIC of Malakasa such as shipwreck survivors
or persons who have arrived in mainland reception facilities (camps) on their own and
remain unregistered there.
Case study: Naiem* and Nooria* are refugees from Afghanistan. They arrived
in Greece through the land border at the end of August 2022 with Nooria’s
daughter and arrived in the Schisto camp in Attica. In October 2022, the camp
arranged their organised transfer as part of a larger group of residents to the
RIC of Malakasa, with a view to the lodging of their asylum applications.
RIS treatment remains unclear as regards the latter case of individual asylum seekers
residing in camps after arriving on their own, however. In similar cases supported by
RSA, it appears that reception and identification procedures in the RIC of Malakasa
are only made possible after an appointment request via the online platform and/or
intervention from the applicants’ lawyers with a request to speed up registration,
particularly for vulnerable persons.26
Case study: Raheel* and her children are refugees from Afghanistan. They
arrived in Greece in mid-October 2022 and reached the “old” Malakasa camp
on their own; the camp now forms part of the RIC of Malakasa. Raheel
repeatedly approached the authorities but received no information on when
the family would be registered. In late December 2022, Raheel’s lawyers urged
the RIC of Malakasa to speed up registration on account of the family’s
vulnerability and pressing health needs. The RIC responded in January 2023 with
a registration appointment. Following completion of the process, the family was
transferred to a reception facility.
Case study: Habibi*, an Afghan refugee, arrived in Athens in early September
2022 and reached the “old” Malakasa camp a few days later. After several
hours, she was allowed to enter and remain there until her registration. Her
husband, Reza*, arrived in the camp one month later. The couple awaited their
25
26
See however, Solomon, ‘«Με εντολή άνωθεν»: Το καλά κρυμμένο μυστικό της Υπηρεσίας
Ασύλου’, 12 December 2022, available at: https://bit.ly/3RaMn0c.
Articles 38(1) and 41(d) Asylum Code.
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RSA REPORT │ 2023