decisions taken in 2022, no more than 450 were appealed (1.3%) according to official
data.23
13. The remedy is also severely ineffective. Out of 450 appeals lodged with the Hellenic
Police against removal orders in 2022, only 12 were granted (2.7%) according to official
figures.24 In cases supported by RSA, Hellenic Police decisions on such appeals appear
to be identical, to lack specific reasoning on submissions and merely to state that “the
foreigner lacks residence documents and the return decision was issued without a
departure deadline, according to the provisions of articles 21, 22, 23 of L. 3907/11”. This
is the case even for asylum seekers who enjoy a right to remain on Greek territory under
EU and domestic law.25
14. The online platform managed by the Ministry of Migration and Asylum has frequently
been out of service since its launch in July 2022, given that it does not offer an unlimited
number of appointments. When a specific threshold of persons requesting registration
at the RIC and Malakasa and Diavata is reached, the platform ‘shuts down’ and does
not offer appointments to new requests. An automated message appears on the user’s
screen, stating: “No available dates were found for the location you selected” and
indicating only the request number, not the person’s details. 26 The platform was
unavailable for the first half of April 2023, as the Ministry of Migration and Asylum had
indicated that “From 1st of April until 17 April there will be no new appointments so that
the backlog is cleared”.27
15. The platform has again shut down since early May 2023 to the time of writing due to a
lengthy upgrade of the Asylum Service information system, “Alkyoni”. This upgrade has
caused disruption in all areas of operation of the Asylum Service, including schedule
of interviews, granting of identification documents, submission of appeals, affecting
thousands of people in the asylum process.28 We also recall that the Asylum Service
was again unable to grant documents to thousands of applicants for most of 2022 due
to technical difficulties in issuing the Provisional Foreigner’s Insurance and Health Care
Number (Προσωρινός Αριθμός Ασφάλισης και Υγειονομικής Περίθαλψης Αλλοδαπού,
PAAYPA) for certain categories of cases.29
16. Even where the online platform operated, it booked appointments for several months
later, reaching even up to twelve months in certain cases. These may subsequently be
rescheduled by the Ministry of Migration and Asylum depending on availability of
capacity.30 Similar issues hinder the booking of appointments for subsequent asylum
applications through a separate dedicated online platform.
17. Information shared by the Asylum Service on 6 July 2023 in reply to a letter by legal aid
actors suggests that the online platform for initial asylum claims on the mainland has
been phased out altogether: “As regards the restart of registration of initial applications
for international protection on the mainland and specifically in the Malakasa and
23
24
25
26
27
28
29
30
RSA, Immigration detention in 2022, April 2023, 3-4.
Ibid.
Ibid.
RSA, Registration of asylum applications in the new mainland RIC in Greece, February
2023, 5-6, available at: https://shorturl.at/pvX04.
European Commission, TF (Task Force) – GR (Greece) Coordination Meeting Operational
Conclusions, Ares(2022)2924004, 14 March 2023.
RSA, ‘The upgrade of the "Alkyoni" system of the Asylum Service leaves processes and
people in the air’, 31 May 2023, available at: https://shorturl.at/zDSV2.
RSA, ‘Refugees without identification documents: The Greek Asylum Service must urgently
resolve technical problems’, 27 October 2022, available at: https://shorturl.at/nrtIL.
RSA, Registration of asylum applications in the new mainland RIC in Greece, February
2023, 6.
8
RSA COMMENTS│ 2023